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Despite heavy lobbying from the industry, there were only a few minor changes as the FCA confirmed its proposed changes to its complaint handling rules (DISP).
We have in the past reported on the complaint handling thematic review (TR14/18), and written of the subsequent consultation paper (CP14/30). When we did, we spoke of using them as a guide to prepare your firm for the final rules. Those days of ‘possible new rules’ are gone, and the new rules have been confirmed.
The policy statement is essentially peppered with clarifications of the rules that were previously consulted on, with the main changes being:
The implementation date for the call charges rule has been delayed to 26 October 2015 (as opposed to the previous date of summer 2015)
Further amendments to the complaints return form detailed in page 23 & 24 of the paper, to be implemented 30 June 2016
The FCA has confirmed that this second change means that reporting systems must be ready by January 2016; a tall order
How to proceed
So now you know timescales are tight, how ready are you? Making the required system changes to facilitate the new reporting requirements is a demanding piece of work. On top of this, if your firm is going to change its operating model to align with the new rules, then you will need to be thinking about the following (if not already completed):
a detailed gap analysis against your desired ‘to be’ state
updating your policies, processes and procedures
revisions to your quality assurance model aligned to your revised operating model
system changes to facilitate the capture of all complaints, including next business day
training requirements, especially if your operating model changes require more complaints to be resolved at first point of contact
Subsequent embedding work should ensue from the beginning of 2016 by taking your people on the journey through effective change management and training, with particular focus paid to frontline staff.
Our White Paper serves as a tool to help you consider how you will implement the rules effectively, and in time. We look methodically at the regulatory drivers of the new rules, and the opportunities and challenges you face, taking you through what good could look like in your firm’s approach. We hope it is of use.
White Paper – Implementing the FCA’s “Improving complaints handling”