The Financial Conduct Authority (FCA)’s recent review on consumer vulnerability and outcomes has re-emphasised that, although some firms are making good progress, there are still areas for improvement.
In particular, they outlined issues around how firms effectively monitor, and act on, outcomes for consumers in vulnerable circumstances. For example, only 39% of firms they surveyed had formal governance bodies in place to oversee and influence outcomes for vulnerable consumers.
This got me thinking about how organisations can better monitor outcomes for all customers in collections. If firms don’t get this right across all consumer cohorts, they will achieve poor outcomes and risk non-compliance with regulation.
In this blog, I will explore the ways organisations can strengthen governance and oversight to ensure regulatory compliance and better customer outcomes.
1. Maintain up-to-date policies and processes
This is critical to ensuring that staff understand expectations in relation to conduct and consumer outcomes.
Policies and processes should always align to regulatory and corporate standards, and include an arrears / collections policy, a vulnerable consumer policy, a forbearance policy, and consumer journey maps.
They should be reviewed and approved by all relevant stakeholders, and available for staff to view at any time. They should also form the basis of frontline agents’ competency frameworks.
2. Conduct regular refresher training for agents
Aside from standard induction training, it’s important to conduct regular training updates for agents. The frequency will vary by topic, but I recommend that the following are revisited regularly to empower agents to continue providing the appropriate treatment paths:
- Latest regulatory compliance
- Vulnerable customer identification and impact
- Building a good customer relationship
- Assessing personal and financial circumstances
- What a good outcome looks like within existing forbearance suites
3. Ensure robust quality assurance frameworks
In order to drive consistency on what good outcomes look like, as well as identify performance issues and risk themes, firms should continuously monitor consumer interactions, journeys and subsequent outcomes.
As a minimum, they should cover:
- Call monitoring that focuses on understanding circumstances, identifying good outcomes that are tailored to the circumstances, ensuring implications are explained to consumers, and enabling remediation activity where appropriate
- Customer outcome testing that focuses on the consumer journey, areas of concern or delays in the journey, and identifying and enabling process improvement
Organisations should not only ensure that they have the frameworks in place but also calibrate with QA analysts and the operational management team.
4. Establish clear performance metrics
Key metrics could include sustainability of repayment arrangements and forbearance outcomes, time conversions through to outcomes, and re-entries to arrears.
All measures should be segmented by consumer cohorts to understand outcomes at different levels of financial stress, vulnerability drivers, and vintage performance of outcomes.
The performance measures above should be supplemented with quality monitoring outputs, consumer feedback loops, root cause analysis of complaints, and affordability assessment data.
5. Implement performance oversight at all levels
Firms should utilise appropriate performance reporting at every level (from agents up to the board), which should include segmented and comparable performance insights based on consumer cohort.
I also recommend implementing governance panels for each of these cohorts (e.g., vulnerable consumers) who should meet regularly to escalate and agree bespoke strategies for relevant cases.
6. Put in place a risk and control framework
Ensure a Risk & Control Self-Assessment (RCSA) framework is in place that captures and assesses the likelihood and impact of all potential risks, the subsequent controls in place, and the net likelihood, and impact following implementation of controls.
This should include control testing and Corrective Action Plans (CAP) where controls fail following testing or at any time through outcome monitoring.
Summary
Ensuring a strong governance structure around conduct and consumer outcomes will support collections operations in achieving good outcomes across all your consumer cohorts, including those experiencing vulnerable circumstances.
Arum can help
At Arum, we have over 25 years of experience helping our clients to deliver better debt outcomes across the world. We can provide independent assurance of policies, procedures, and operations to ensure compliance with Consumer Duty, CONC, PS24/2, and vulnerability guidance while driving good customer outcomes.
Take a look at our helpful resources below or contact us directly to discuss your needs.
See how we improved Newcastle Building Society's customer outcomes with training and assurance interventions
Read how we helped Aldermore bank to improve results with our good outcomes training
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About the author
Darren Furlong
Principal Consultant - UK & Ireland
Darren has over 25 years of experience in collections and recoveries across financial services, holding senior roles at institutions like Barclaycard and UK Asset Resolution. He has led large teams, managed complex operations, and delivered significant improvements in delinquency rates. Darren specialises in collections transformation, implementing effective strategies, enhancing customer outcomes, and ensuring regulatory compliance.