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ABI complaints thematic breakfast briefing

The ABI hosted a briefing on March 27, 2014 where the FCA discussed the current Thematic Review on Complaints Handling, the approach taken and progress to date.

The main points of discussion were:


In September 2013, the FCA announced plans to carry out a thematic review of complaint handling in banks, building societies and insurers, placing greater onus on the role of senior management.  They said that the amount of complaints that go to the ombudsman suggested that something wasn’t working in the way in which firms manage and investigate customers’ complaints.  The review commenced in November 2013 to identify why complaints handling is not working well for consumers and to address any poor practice within firms. It was split into two phases; phase 1: looking at how firms identify, record and report complaints (now completed) and phase 2: looking at how firms approach to redress and analysis of the “root cause” of complaints.

Progress to date


14 firms were selected to participate in the thematic review across retail banking, home finance, GI, life & pensions and investments.  They were joined by trade bodies (ABI, BBA, BSA, CML), and the FCA in a working group to consider issues arising out of the analysis and make recommendations to the FCA. This working group was a new way of working for the FCA, and the role of the trade bodies was to help share good practice and when bad practice was identified, to help the FCA understand why.

Phase one

The firms were given six dummy complaints scenarios to see how that firm would deal with a complaint, with a focus on what happens in practice as opposed to the policy. A template was provided for reporting back and a presentation was given on that template to the supervision team. All firms have now received feedback on their assessments and many good practices were found, including the use of customer surveys and asking for customer feedback.

However, the results did indicate that firms with multiple distribution channels and de-centralised complaints structures face more challenges than mono-line businesses with a centralised complaints function.  

Working Group Recommendations

During phase one, the Working Group considered issues that had arisen when firms were carrying out the dummy scenarios, and proposed 5 recommendations to the FCA in how to address these concerns. Concerns related to premium telephone lines, complaints identification (definition of complaint), recording of complaints (next business day requirement) and reporting of complaints (annual returns). These recommendations (pdf 206kB), have gone to the FCA for consideration. Please bear in mind that the FCA have some way to go before we know if they will be adopted as Policy, including a formal consultation process where the whole industry can provide their comments.

Phase two

Phase two is currently being carried out and is due to complete by the end of April. This is about internal reporting and is mostly about MI. Questions will focus on how efficient it is, qualities of outcome and how to use the MI correctly.

Next steps

The FCA expects to publish its final report on the thematic review in June and will issue a consultation on the DISP rules which is expected in Q3 to reflect any potential changes that are needed following the thematic review. 

Last updated 01/07/2016