A UK retail bank had proactively identified their complaint handling processes, for the sale of investments and associated advice relating to life and pension products, as an area of urgent focus for its Customer Fairness Review programme.
At the outset, the bank needed to assess the historic handling of upheld and rejected complaints relating to retail investment products to determine whether the original complaint handling processes and decisions had met with regulatory expectations and delivered fair outcomes.
Depending upon the outcome of this assessment, the bank acknowledged an additional obligation to update the regulator of its intention to conduct a broader past business review and develop a comprehensive plan as to how this would be achieved.
PwC mobilised a team of investment advice subject matter experts to undertake the initial analysis. The team reviewed 1,500 advised investment complaints raised between 2005 and 2013, and – at the request of the bank - completed the review of 500 investment advice events that were completed during the same period.
In light of the levels of unsuitable advice and product sales (and the assessment of associated complaints), the bank commissioned a past business review. PwC supported initial discussions with the FCA in this regard and helped define the scope of the review, working closely with the bank’s data teams to identify the most vulnerable customer groups.
PwC developed a comprehensive plan to scale the pilot operation of 18 FTE to an appropriate investment advice review team of 90 FTE over an 8 week operational transition period. The plan detailed all aspects of the PBR, from data analysis and data gathering across legacy systems and archives, through to customer review policy and processes, redress calculation, and customer liaison (including complex customer scenarios).
Crucially, the plan also set out quality assurance expectations, detailed how PwC would provide appropriately qualified and experienced resources to support each PBR function, and included the system-driven MI that the regulator could expect.
The plans met with the approval of the regulator, and mobilisation activities began immediately.
Director, Customer Management, PwC United Kingdom
Tel: +44 (0)7525 280911