Change Management : Make or Break

As we enter 2019, a number of changes lie ahead for the financial services sector. There’s the long-awaited Motor Finance paper, the end of PPI, Retail Distribution Review (RDR) on Financial Advice, Claims Management Companies (CMC) Authorisation, Senior Managers Certification Regime (SMCR) within Consumer Credit and over the last couple of days, the FCA’s probe into cryptocurrency transactions. These are just a few of the areas of regulatory focus, all of which will result in industry change in some form.

In its 2018/19 business plan, the FCA is very clear on its expectations on firms’ culture and governance across all sectors. The key is being able to demonstrate that compliant, positive behaviours are being driven to ensure that consumers benefit from the right outcomes.

Below our Change Consultant, Tony Jobson, shares his insight on change, how preparation and prioritisation can support your business throughout change, big or small.

“So, what is it about Change?

This simple word can create a whole range of emotions in us. Excitement, fear, apprehension, denial – all can appear and disappear in moments or become barriers for us as we move forward.

When we think about Change it is often in the context of physically doing something differently; moving to a new house, getting married or divorced, starting a new job, being made redundant or changing career direction. Change can be directly related to us as individuals, impacting on our lives and the way we do things. We may instigate the change, or more often, it is as a result of decisions made way beyond our control.

World politics, the turbulence of economics, natural events – being in the wrong or right place at the wrong or right time – we sometimes have no say in how a particular piece of change begins or how it develops. What we can have some control over is how we understand, react and embrace or reject the different circumstances we find ourselves in. Of course, in history, there are countless examples of people doing extraordinary things in extraordinary situations, which draw awe and admiration from observers.

However, I’m more interested in ‘ordinary change for ordinary people’. Back in the day, asking someone to move desks or maybe offices were major events. Today, as technology frequently becomes a common part of the workplace, we still have those internal feelings. How we understand and deal with our reactions is something we can do something about – we just sometimes need a little help, or more importantly some space to think and breathe!

How often do we hear about a change in process going wrong? A new system being introduced and the time needed to be invested afterwards to ‘correct’ the way of working? Training in new regulations that becomes a battle of wills rather than a smooth transition? Or increasing productivity but destroying colleague engagement along the way?

My submission is that these scenarios play out all too often.”

How can Kind Consultancy help?

Looking carefully at how we prepare people for forthcoming change events can make or break a team, business or industry. At the very least it can stall progress. Consider Brexit … with just three months to go – the apparent lack of planning, conflicting personal and political agendas together with ill-judged negotiating has led to paralysis in the boardroom, investment in industry drying up and near-panic for companies who trade with European neighbours. Sound familiar? It’s a classic Change case study!

Kind Consultancy has been supporting organisations in Governance, Risk and Compliance for the last 6 years, with access to experienced individuals who have been part of the of the change revolution and have been involved in successful and unsuccessful change programmes. This experience coupled with a unique approach to the People Side of Change allows them to help leaders, teams and individuals on their own change journey.

Typically, our consultants will look at key aspects of a business, such as culture, leadership, reward & recognition. This flexible framework can guide business leaders of all levels on a path of prioritisation, coupled with individual and team discussions, coaching and mentoring sessions, best actions can be agreed to achieve business objectives.

For more information on how Kind Consultancy can support you, please email info@kindconsultancy or call on 0121 643 2100.

More Focus On General Insurance Regulation?

At the end of last month, the FCA fined Liberty Mutual Insurance Europe SE over £5 million for failures in their oversight of mobile phone insurance claims and complaints handling processes administered through a third party. Liberty held regulatory responsibility for ensuring claims and complaints from customers were handled fairly.  In the 2018/2019 FCA Business Plan, third-party outsource was named as a key area for review and this is the most high profile case involving it so far this year. The Business Plan states that they’re concerned about the ever-growing number of authorised firms outsourcing crucial procedures to unregulated third-parties, and the FCA are looking to re-enforce the fact that firms will be held responsible for the failings of anyone they subcontract compliance or complaints work to.

This is also the latest FCA case focussing on a general Insurer, another area the regulator has been giving greater focus to recently. The scope of Insurance regulation could expand further in the near future with the FCA currently running a probe on car and home insurance pricing and transparency around renewals.  Adding to the FCA’s wider work on “loyalty penalties” and the cross-industry problem of long-time customers sometimes getting worse deals than new ones, we’re looking at a lot of potential issues that could create new KYC problems for the industry, for example; where customers are looking for credit to pay for their insurance premiums, affordability checks could prevent them from renewing with their preferred insurer.  In addition to this, the Senior Managers and Certification Regime (SMCR) will be applied to General Insurance from December, creating a whole new set of responsibilities, fitness and propriety testing requirements for senior management across the sector.

Kind Consultancy is currently having discussions with a number of insurers regarding review of their practices, processes and procedures. If you need experienced, knowledgeable compliance and complaints contractors, we have a pre-qualified bank of industry-leading interim talent who can quickly and efficiently join our clients to support current and future projects relating to these issues. For a confidential conversation about your regulatory needs, contacts selena@kindconsultancy.com or call  0121 643 2100.

– Selena Tye

Kind Consultancy Announces Major International Project – Bringing Market-Leading Risk & Compliance Talent to Australia

Kind Consultancy is very proud to announce the commencement of a major international project in partnership with a Big Four consultancy. We’re looking for Manager, Associate Director and Director-Level Consulting professionals in the UK with experience of Enterprise Risk Management and the design and implementation of risk frameworks, who are interested in relocating to Australia. We are also interested to hear from Regulatory Advice specialists at Manager through to Director level.

Our client is committed to getting the very best talent for these crucial roles and as such is willing to support visas and assist with relocation costs. The roles will be based in Sydney and Melbourne and will focus primarily on Financial Services projects, with some possible work in local government as well.

Kind Consultancy Director, Lynsey Moore says that this project “represents a truly life-changing opportunity for the very best Risk & Compliance professionals to do exciting work in one of the most desirable locations in the world”

If you match the above description and you’re interested in relocating to Australia to join one of the global leaders in Risk and Compliance consulting, submit an up-to-date CV to info@kindconsultancy.com with the subject line ‘Australia Project’.

Kind Sponsors Cancer Research Wolves

Kind Consultancy and Kind Wealth are very proud to have sponsored the Cancer Research Wolves for the last two seasons. The Cancer Research Wolves are a Rugby 7s team created to raise awareness and money on behalf of cancer charities. Fielding both men’s and women’s teams, the Cancer they have raised over £22000 over the last two seasons and we’re very happy to have been a part of that amazing success. Rugby 7s is a form of Rugby Union that sees seven-a-side teams competing in explosive seven-minute halves, making for an entertaining, action-packed sport that has become more and more popular over the last few years. Congratulations to all of the team, the coaches and their loyal supporters for all the work they’ve done for a very important cause.

Insurers to Review Commitment to Loyal Customers

In all types of Financial Services products, one of the complaints you hear most frequently is that you have to frequently switch providers to get the best deal, by taking advantage of special rates and offers that are only available to new customers. The insurance sector is currently facing particular criticism on this front, with a new Which? investigation this week finding that customers with combined policies owned for longer than a year were paying on average 38% more than new customers. The results only get more concerning over time, with policies that were four to six years old found to be 54% more expensive compared to prices paid by new customers.

Earlier this year,  the Association of British Insurers and the British Insurance Brokers Association announced a list of “action points” aimed at tackling this problem, with an overall goal of “reducing excessive differences between premiums for new and existing customers”. Firms belonging to either of the two industry bodies will pledge to take preventative measures to ensure that loyal customers are not “unfairly penalised” at renewal time. They will also need to reassess the fairness of pricing strategies, with insurers reviewing their pricing for customers who have been with them for over five years.

The plan applies to home, motor and travel insurance, but so far pet and health insurance are not included. In a press release this morning ABI chairman Andy Briggs said “The renewal market simply doesn’t work where loyal customers get charged much more than new customers” and that “These new guiding principles and action points are a positive initiative by the ABI and BIBA… to demonstrate that the whole industry recognises this is an important issue that needs to be addressed”

The treatment of existing customers is also on the minds of regulators, with it highlighted as a key priority in the FCA’s 2018/19 Business Plan.  The plan stated that they “aim to ensure that existing customers enjoy the benefits of increased competition and innovation” and that “firms should not give longstanding customers less attention than new customers or treat them in a way which results in poorer outcomes.” They did note that many firms have made progress on centring existing customers in their business models, and while there has definitely been a growing recognition of this issue in the industry over the last decade, there’s still a long way to go. Hopefully, with these new ABI/BIBA plans, the insurance sector can lead the way in prioritising and rewarding longstanding loyal customers.

Expert Recruiters and The Kind Difference

Kind Consultancy prides itself on being a specialist firm of expert recruiters. But what does that mean? How are we different from the average recruitment agency?

When a new recruiter joins a firm, they’re often plunged into a few days of intensive training, memorising scripts and going through role-play exercises until they have a handle on how they’re going to be working. Some recruitment agencies go one step above this with continuous training, regularly refreshing consultants to keep their skills sharp. People will then go to market claiming to be “experts” when in reality they have a shallow understanding of the roles they’re working on that doesn’t go much further than a job title.

We believe it’s important to not just understand recruitment processes, from initial client briefs through market mapping to interviews, completion and post placement care, but also to aide our consultants and, subsequently, clients and candidates with specialised, specific Governance, Risk & Compliance and Complaints industry knowledge.

The Kind Difference is that as well as equipping our team of recruiters with a variety of techniques to make them excellent recruiters and making sure they’re continually honing their abilities, we also regularly train the team on industry topics and specific role knowledge – just this month, for example, they’ve completed Financial Crime and AML regulation training, as well as Treating Customers Fairly. As well as this formal training, Kind Consultancy works alongside the other parts of the Kind Group who are themselves Financial Services organisations regulated by the FCA, exposing us to regulatory changes and upcoming topics on a daily basis.

This means that unlike any of our competitors when you talk to a Kind consultant you’re talking to someone who actually understands your role, how it works and how it relates to the rest of the business. As a client, you can be confident that your role will be approached strategically, with candidates selected who fit your organisation’s specific role needs and wider business plans. As a candidate, you know you won’t be wasting time explaining every acronym on your CV or being submitted to jobs that are only loosely related to your experience and skill set.

The next time you encounter a recruiter self-describing as an “expert” in your field, ask – what makes you an expert? What exposure to the actual industry have you had?

If you’re seeking career advancement within Governance, Risk & Compliance or Complaints, or your organisation has resourcing needs, contact us at Kind on 01216432100 or info@kindconsultancy.com for a confidential discussion.

Regulator Calls for Simplified Pension Choices

Do customers need simpler pension choices? Last month’s Retirement Outcomes Review saw the FCA calling on providers to simplify retirement choices, improve customer engagements and most interestingly to establish drawdown “investment pathways”.

The FCA suggests that these pathways would be ready-made options, designed to enable consumers to either take the money over a short period, take money as an income in retirement or stay invested for a longer period of time with only occasional withdrawals. Three years on from the pension freedom reforms that made many of the current invest-and-drawdown schemes possible, the FCA is concerned about the value for money in drawdown, especially the significant variance in charges which are sometimes complex and difficult to compare. The FCA plans to force firms to show a straightforward one-year charge figure in pounds and pence in the key features illustration they provide customers. They also made it clear that they have “not ruled out” bringing in a cap on drawdown charges and hinted that this might be used against firms that don’t introduce investment pathways.

The FCA’s research shows one-third of drawdown consumers 100% invested in cash, and they believe half of those are likely to suffer on income in retirement. The new rules would force consumers to take an active choice before being placed into cash. They also found that as many as 60% of consumers had not taken any advice about drawdown and were not sure about where their money was invested and that customers could be receiving up to 37% more retirement income by investing in a different mix of financial assets rather than cash.

If this creates a new area for customer complaints or remediation, Kind Consultancy is perfectly positioned to supply you with both interim and permanent resources with extensive experience and expert-level knowledge in this area. Contact us on 0121 643 2100 or e-mail selena@kindconsultancy.com.

Selena Tye

Building Societies and the Future of Retail Banking

For those following Financial news over the last few months, it can seem like quite a dark time for Building Societies, retail banking and the mortgage space, with a lot of doom and gloom surrounding “mortgage prisoners”, affordability rules and the possibility of an apparently impending interest-only mortgage time-bomb. There’s a sense of panic amongst some customers, who fear raising the issue with their provider, thinking perhaps they’ll be asked to pay immediately and be in an even worse situation.

Personally, I believe that this is a very exciting time of great opportunity for Building Societies to really show why they can be a fantastic alternative to traditional big banks for some customers. Speaking at the Building Societies Annual Conference last month, the FCA’s Director of Supervision (Retail & Authorisations) Jonathan Davidson spoke about Building Societies being perfectly positioned to provide unique solutions to consumers. Of course, the ability to provide complex products needs to be balanced with a strong understanding of the complex risks that come with it, and affordability and lending risk considerations will continue to be crucial for organisations of all sizes. We’re already seeing some unique responses to recent issues from the Building Society markets, with a number of them announcing, for example, Retirement Interest Only Mortgages, a product very specifically designed to help their customers avoid these problems, and YBS announcing that they’re completely abandoning “Early Redemption Charges”.

Mark Marsden of Beverley Building Society commented that: ‘Our individual manual underwriting processes specifically provide for helping ‘mortgage prisoners’ access all our competitive mortgage schemes and we consider doing so to be an important contribution to our social purpose of helping support sustainable homeownership’. Beverley has also recently broadened the availability of interest-only lending to older borrowers (including those in retirement) and will be launching a Retirement Interest-Only product later in the year.

Mark welcomed the FCA’s initiative in this area commenting that ‘in normalising the provision of these types of loans the regulator has greatly assisted lenders to accelerate product development by reducing uncertainty around the interpretation of the associated conduct risks and ensuring minimum standards of protection for customers. Retirement Interest-Only mortgages will not be suitable for everyone, but can satisfy existing and emerging needs in a very cost-effective way’.

If your organisation needs Regulatory Compliance expertise, contact Kind Consultancy on 01216432100 or e-mail selena@kindconsultancy.com

High-Cost Credit FCA Review: Changes Afoot?

Are people using more high-cost credit? Earlier this week the Financial Ombudsman Service published their annual review, which showed an overall 4% rise in banking and credit complaints. Excluding PPI, consumer credit complaints accounted for 24% of all new complaints over the last year and the numbers get even more concerning when we look at the increases in complaints about specific credit products and services. Complaints about payday loans are up 64%, complaints about hiring, leasing and renting are up 73%, and complaints about home credit have increased by a staggering 146%. 1 in every 4 new complaints that wasn’t about PPI involved consumer credit in some way.

To some degree, these numbers are the result of the increase in the number of people using credit and the amounts involved rising – it is clearly a key area for regulatory change in the immediate future. Should financial businesses be doing more to help customers plan for and avoid the risks that come with high-cost credit? What can they do differently?

Yesterday, the FCA published the outcomes of their high-cost credit review, setting out new proposals designed to protect people who use high-cost credit and overdrafts. They’re bringing in some immediate changes concerning transparency around overdrafts, with the end goal described by Andrew Bailey as “rebalancing in favour of the customer”, but they’re also now seeking input for consultation on a much wider-ranging set of changes still to come. While the overdraft issues are grabbing the most media headlines, the same review also has news concerning home-collected credit and catalogue credit and store cards – with plans to strengthen protection for vulnerable users of high-cost credit, raising standards in sales practices and disclosures and introducing new controls on refinancing. The FCA is estimating that these first set of changes alone will save consumers over £34 million per year, and I’m sure we’ll see even more sweeping changes after their consultation period.

Selena Tye

The FCA Plans to Free ‘Mortgage Prisoners’

The FCA’s long-delayed interim Mortgage Market report was finally published last week, and one key finding has spawned gloomy headlines; the UK has roughly 150,000 “mortgage prisoners”. These are people ‘trapped’ in expensive mortgages who are unable to move to a better deal because of the stricter affordability checks brought in back in 2014.

The report also found that around 30% of all borrowers have failed to find the cheapest possible mortgage for their circumstances. The same report did find that there are high levels of choice and consumer awareness in the mortgage market right now, but customers still don’t have a clear way to be confident of which mortgage deals they qualify for and the FCA report said this was “a significant impediment” to people finding the best possible deal.

The good news is that the FCA and the Financial Services industry seem to be in agreement that this situation can be improved. The FCA wants to develop a solution that makes it easy for borrowers, early in the process, to see and compare the products they qualify for, and they’ve also discussed working with the intermediary sector to help consumers compare mortgage brokers. For those “mortgage prisoners”, the regulator is looking to reach a voluntary arrangement with the lenders involved to switch the affected customers on to new, better deals. The FCA is looking to publish a final report late this year, more fully exploring potential remedies to the current problem.

On the side of the lenders, brokers & intermediaries, we may see an increase in demand for CeMAP qualified interim resource to handle any new FCA directives that come out of this report. If you want to discuss your organisations specialist mortgage or compliance recruitment needs, contact Kind Consultancy at any time on 121 643 2100 or e-mail info@kindconsultancy.com.

Selena Tye

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