2. Complaint Handling

3. What is a complaint ‘ Any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the firm’s provision of, or failure to provide, a financial service’.

4. Who looks into a complaint The firm must appoint a “complaints champion” to deal with all complaints. The “champion” should be a senior manager (e.g. A director, not a compliance manager.) The firm should document in their internal company procedures who the “champion” is ”

5. Receiving a complaint A complaint can be made: In person By a third party with consent from the complainant (e.g. a complaints handling firm) By Post By Telephone By Fax Via E- mail

6. Who responds to a complaint Anyone in the company can receive a complaint. The complaint must be passed to “the champion” who will then respond following the complaints procedures.

7. If a complaint can be addressed by the next business day: Customers are happier, leading to improved customer loyalty Any weaknesses in systems can be identified to reduce future similar complaints Customer correspondence is reduced There is no need to report complaints resolved within one business day to the FCA

8. Putting things right could be simple as: Carrying out a simple fact check into what happened Verbal acknowledgment of poor service and an apology (and, if relevant, what action you’re taking) Verbal feedback offering clarification if you think the client may have misunderstood Verbal confirmation that action has been taken to correct an error If possible, verbal reassurance of what you’ll do to prevent it happening again

9. Remember Customer complaints can be viewed as an opportunity to improve your systems and therefore your customer service

10. CUSTOMER ETIQUETTE Do’s and Don'ts Do: Introduce yourself Get straight to the problem Take client’s details Explain company complaint procedure Stay calm with an angry client, Accept a complaint (if you feel it’s justified or not) Talk in language a client will understand (No jargon)

11. CUSTOMER ETIQUETTE Do’s and Don'ts Don’t: Argue with client Bury or ignore the complaint Make it difficult for the client to complain Ask a client to complain in writing Accept abuse from an angry customer Accept a complaint if it is about you - pass it to a colleague Comment on the validity of the complaint

12. Key FCA Complaint Handling Rules: The FCA rules on complaint handling are found in the FCA handbook under DISP. The purpose of the complaint handling rules is to ensure that complaints are handled fairly, effectively and promptly and resolved at the earliest opportunity, minimising the number of complaints, which need to be referred to the Financial Services Ombudsman (FOS). These rules are consistent with the FCA’s consumer protection regulatory objective.

13. Who is an eligible complainant? A retail client; A business which has a group annual turnover of less than £1 million at the time of the complaint; A charity which has an annual income of less than £1 million at the time of the complaint; A trustee of a trust which has a net asset value of less than £1 million at the time of the complaint;

14. Who is an eligible complainant? A beneficiary under a trust or estate of which the firm is a trustee or personal adviser; or The original beneficiary under a contract of insurance. The beneficial owner of units in a collective investment scheme with a complaint about the scheme operator or depositary A beneficiary of a stakeholder/personal pension scheme

15. Key FCA Complaint Handling Rules: You must inform customers of your complaint handling procedures at or immediately after point of sale or on receipt of a complaint. Complaints should only be investigated by someone who has been assessed as being competent. Written acknowledgement to be sent promptly Complaints should be resolved within 8 weeks from when complaint was first received, the final response must also inform customer of FOS referral rights and include FOS leaflet.

16. Key FCA Complaint Handling Rules: If at 8 weeks you are not in a position to make a final response, explain the reasons for the delay and indicate when the firm expects to be able to provide a final response, if clients are dissatisfied with the delay they have FOS referral rights.

17. FOS Jurisdiction The FOS can consider complaints in relation to FCA regulated activities The FOS may also be able to consider complaints in relation to activities that would have been subject to a former dispute scheme such as The Dispute Resolution Facility established by the General Insurance Standards Council and the Mortgage Code Arbitration Scheme

18. Key FCA Complaint Handling Rules: From 31 December 2012, you must submit complaints notifications for your retail investment advisers within 20 working days: whenever three complaints are upheld relating to an individual investment adviser in any 12-month period, or where a complaint is upheld and redress paid exceeds £50,000. Complaints against individual retail investment advisers for activities which occurred before 1 December 2001 do not need to be reported.

19. Key FSA Complaint Handling Rules: Complaints records must be retained for min 5 years for MiFid business & collective portfolio management services for UCITS schemes and a minimum of 3 years for all other business Complaint details in relation to firm and individual investment advisers are submitted twice yearly to FCA via Gabriel / RMAR.

20. Complaint Documents Customer complaint acknowledgement letter Customer complaint final response letter Customer complaint register The company complaint procedure document (must be given or sent to Clients on receipt of the complaint)

21. Complaint handling We ask you now to complete a short test to confirm your knowledge of the Complaint Handling process.