The rules and principles which apply.

The Consumer Duty support outcome refers specifically to the requirement that customers should face no unreasonable barriers to making a complaint.

The FCA Handbook contains specific rules and guidance relating to claims handling (see the DISP Sourcebook) which are themselves heavily influenced by delivering good customer outcomes; indeed guidance in DISP 1.1.1 states that complaints should be dealt with promptly and fairly.

Some key questions which the FCA has raised in relation to complaints include:

• How firms identify trends and remedy issues arising from the handling of customer complaints which may indicate a wider or recurring problem.
• What targets firms set for staff handling complaints.
• How lessons learned from complaints are shared between different business areas.
• What is done to ensure the outcome offered to a customer’s complaint is full and fair?

How this may affect you.

Chapter C of this Manual covers the requirements of the DISP Sourcebook and includes the rules that firms must meet to ensure good customer outcomes are achieved from the complaints handling process. The guidance in this section is designed to cover good practice suggestions and should be read in conjunction with the complaint handling rules which must be fully complied with at all times.

We recommend firms have a written internal complaint handling procedure and that all staff receive training in recognising and handling complaints and refresher training at appropriate intervals.

The download documents in Chapter C of this Manual provide sample internal and external complaints procedures together with sample response letters.

In addition, firms may wish to consider the following good practice points in helping to create a positive complaint handling culture:

• Avoiding a business culture which is predisposed to view the receipt of complaints negatively as time wasting or mainly unjustified.
• Ensuring staff are encouraged to view complaints as useful, valuable, and positive feedback and not just as a compliance or legal task.
• Reassuring staff that complaints are monitored not to allocate blame but to ensure customers are provided with the best possible service and outcomes.
• Aiming to settle all complaints fully and fairly without the customer having to have recourse to the FOS.
• Taking prompt action to address complaints where they are justified, and providing appropriate redress when the client has suffered a financial loss or has been unable to fully utilise the product or service they have purchased.
• Ensuring information gathered through complaints is shared with other parts of the business.
• Recording all complaints to generate useful management information and regularly reviewing this to identify where issues are recurrent or systemic.
• Taking action to address systemic issues to reasonably prevent the recurrence of complaints.
• Reviewing complaints management information to identify where the subject matter of complaints received could affect groups of customers (including those with identified characteristics of vulnerability) and taking appropriate action to address any issues proactively across the group of customers affected.
• Ensuring the full and fair investigation of any complaint.
• Ensuring a consistent decision-making process by providing adequate guidance and training for complaints handlers and sampling complaint responses to monitor consistency.
• Ensuring a consistent approach regardless of the value to the business of the customer who is complaining.
• Being proportionate and fair when applying the time barring rule.
• Ensuring clarity and use of plain English in all communications.
• Recording not only complaints as defined by the DISP rules but also negative feedback which may not constitute a reportable complaint under DISP but may provide a useful indicator of issues that could be addressed to prevent issues from escalating or becoming a systemic issue.