Identifying Systemic Issues and Improving Customer Service Annette Donselaar ASM BA BCom MComLaw LLM DFP Grad Dip Compliance AACI Head of Australian Region Compliance

> Why complaints and compliance teams need to work together > Systemic analysis in practice - why doesn’t it always work? > Strategy into action > NAB – a case study > Benefits and ongoing maintenance Agenda

Does this sound familiar? > We have a wide range of breaches but why don’t know why they occur. > We capture information about our customer complaints but we have difficulty truly understanding what irritates customers. > We have a ‘gut feel’ about what is going wrong but we can’t quite put our finger on it. > We need funding to address some issues but we don’t have the statistics to back it up. > Customers tell us that we have certain problems but it is not reflected in our data.

The link between complaints & compliance > If you could identify with any of the statements, you are searching for a better way to understand your compliance environment - environmental data (especially complaints!) is critical. > By creating open lines of communication between complaints & compliance teams you can:  Identify and prioritise the critical impact issues on customers and the organisation  Enhance data quality and integrity by focussing on classifications, relationships and significance  Providing meaningful data to prove (or disprove!) folklore  Enable differentiation between symptoms and cause

Systemic analysis > Systemic analysis is seen as the ‘cure all’ to support this process. However … –Focus tends to be on immediate resolution by customer facing staff - rather than broader analysis. –Data collection tends to support individual resolution. –Data input is not always seen as valuable by staff - the problem is fixed so why record it? –Due to the nature of information collected, analysis tends to focus on broader issues rather than product or service. –Lack of integration of complaints data with broader risk events.

Strategy into action > Complaints and Compliance teams developed a joint project to address deficiencies in systemic analysis. > Purpose was to ensure that: –staff understood why data is important –ensuring better analysis of data captured –closer working relationship on testing, analysis and response to data collected –Post implementation reviews

Strategy into action > Complaints training to become mandatory compliance training for all customer facing staff. > Complaints and compliance teams review monthly extract of complaints data -lag indicators for trend analysis. > Appointment of systemic analysis manager for complaints data who works closely with compliance staff. > Information integration: –trending and indexing data from BFSO database –risk profiling information across products –continuous improvement on capture tools and lead indicators.

NAB – Our approach > Potential systemic issue identified - either through BFSO, CCMC or by own analysis. > Business unit analysis of issue with compliance team to determine breadth and significance. > Once systemic issue confirmed: –Regulator/complaints body engagement program and information determined –Dedicated workstreams created to address fundamental issues –Regular reporting and briefings to stakeholders (including ACA where appropriate) –Post implementation review to identify lessons learned.

Workstreams > Stop and Remedy –short term fix (‘stop’ the problem) and long term remedies > Quantify and Analyse –Identify extent of the problem > Communication –strategy for internal and external information (letters, adverts, internet) > Compensation –principles and business rules

Benefits > ‘Future proofing’ systems through knowledge of actual and potential breakdowns. > Better intelligence to identify trends of potential and actual failures. > Early warning of systemic issues through business understanding, ownership and commitment. > Focus on the symptoms rather than the causes, and understanding addressing systemic issues is not a quick fix.

Ongoing Maintenance > Critical element is sustainability – ensuring that:  Ongoing measurement program is embedded in the compliance function and supported by the business.  Monitoring of issues with reporting of systemic trends to senior management.  Data integrity reviewed and interrogated on a regular basis.  Feedback loops to prevent reoccurrence developed, monitored and reviewed.