On 21 October 2016, we blogged that the FCA published Thematic Review 16/8: Packaged bank accounts (TR16/8). TR16/8 sets out the FCA’s findings on packaged bank accounts, assessing how firms implemented the packaged bank account rules in the Insurance Conduct of Business sourcebook that the FCA introduced in 2013.
Following the publication of TR16/8 the FCA committed itself to reviewing more recent complaint handling standards, specifically relating to complaints where a customer claims that their packaged bank account was mis-sold.
The FCA has now completed a follow-up review, covering complaints received by firms between March and May 2016. The FCA’s findings include:
- in terms of customer outcomes, firms have made progress in how they investigate complaints. For example, the FCA found that firms had improved their approaches to gathering customers’ testimony. However, the FCA also found that firms could do more to ensure consistency in how they deliver fair outcomes. Where the FCA identified opportunities for further improvement, these were in line with the themes already set out in TR16/8 (pages 21 to 23 of TR16/8);
- in terms of final response letters, the FCA found that firms could make improvements such as: (i) setting out letters in a way that was helpful and clear to the customer. This included using sub-headings or sign-posting where appropriate, and detailing the investigation in a logical way; (ii) using information that is specific to the customer, rather than relying on generic information and/or assumptions that are irrelevant to a customer’s individual circumstances; (iii) setting out clearly and accurately what the firm has understood the customer’s concerns to be; (iv) accurately reflecting the investigation that was actually undertaken; and (v) fully addressing every complaint point (or key theme, where there are multiple complaint points that can be grouped together; and
- in terms of record-keeping, firms could improve the audit trail in the complaint files.