LSB has published its April review of complaints, covering:
- Policies and procedures: All subscribers reviewed had established processes to deal with complaints due to the requirements specified under FCA’s DISP rules. However, there were limited procedures in place to ensure that, once identified, complaints were reviewed against the Lending Code (Code). In most cases the Code was not specifically referenced as a complaint category.
- Controls: Three subscribers had revisited the operational processes and procedures to ensure their current approach was capable of capturing potential systemic issues in relation to the Code. One firm subsequently introduced a “Lending Code Tracker”, a monthly Lending Code Forum and a bi-annual surgery where complaints could be assessed for materiality.
- Monitoring and oversight: Complaints resolution resided in subscribers’ first line complaint handling or product functions. Responsibility for the review and challenge of this information resided with second line compliance or risk teams.
- Training: As most firms did not view the new Code requirement as a change, training on it was limited and firms could not evidence it. However, two subscribers did provide bespoke training to complaints handlers.
- Audit and compliance reviews: One firm carried out post-implementation reviews to assess the extent to which these provisions are being met in practice.
The report concluded that all subscribers taking part in the review had policies and procedures in place to deal with complaints and identify potential systemic issues, and there was no reason to strengthen the Code. (Source: Lending Code Review of Complaints April 2015)