Perfecting the Process: Top Tips for Candidates and Hiring Managers

As a slight change of pace from our usual industry analysis, I wanted to share some tips on how to make the most of the recruitment process – for both candidates and hiring managers. Sometimes small changes can make a big difference, and altering how you approach the recruitment process can benefit everyone.

Being The Best Candidate You Can Be

Recruitment should be a meritocracy – the job goes to the candidate who is best qualified for the position, has the most relevant experience, is the best fit with the team they’ll be joining. So what do you do if you’re up against 3 other people who have held the same titles as you, taken the same industry qualifications, present seemingly near-identical CVs? In the specialist markets we work in, it’s not so unlikely.

First Impressions: CVs

If you and the other candidates for the role are putting forward roughly the same information, exactly how you present that information can be a big differentiator. In terms of CVs, the biggest mistakes I see good candidates make are to do with consistency – make sure that you’re formatting each of your roles in the same way (i.e.. the same order of Title – Company – Dates appears throughout your Career History) and highlighting the elements of those roles which are most relevant to the position you’re applying for.

Customising your CV for the specific application might take a little more time but it makes a big difference – if you’ve put the relevant element of a role right up top and someone else has buried it halfway down a long list of responsibilities, you have a better chance of getting noticed. This is also part of why it’s not a good idea to just copy and paste what you did in a role from the official job specification – writing up the relevant parts of the job will make a clearer argument for why you’re the best candidate.

Similarly, make sure your LinkedIn profile is up to date and that you have a consistent level of detail about your skills and experience across all of the relevant positions. I can almost guarantee at this point that anyone considering your CV is also going to have a quick look at your LinkedIn profile and check for consistency between the two – it’s one of the fastest ways an employer can check if someone is falsifying their job titles, for example. You should never put anything on your CV or LinkedIn that isn’t true – but you can and should make sure that you’re sharing the information that presents that you in the best light for the specific position you’re pursuing.

Concision is your friend when it comes to CVs – if you have all the most relevant details up front and then pages and pages of minute detail on previous roles, those pages are quite likely not being read at all. Just as you should edit your descriptions of recent work to keep the key points clear, I also recommend tidying up roles further back in your career that will be less meaningful to your potential employer. Reducing any roles more than 10 years old to an Early Career Summary section with just dates, companies and titles can save a lot of time and space – and save you from a hiring manager opening your CV and balking at the page count before they’ve even began reading.

Do Your Research

Find out as much as you can about the company, and their specific recruitment process. From the specific format of the interview to their current marketing campaigns, the more you know about the company, the better prepared you are, and the more specific you can be. By this point I think “It’s important to ask questions of the interviewer” is the first piece of advice everyone gets and it’s absolutely true but there’s a big difference between an uniformed question and one that shows you’ve already found out as much you can about your potential new employer on your own.

Know Your CV

It may seem obvious but you would be surprised how often candidates will be unprepared to talk about something on their own CV. Once you’ve customised the document itself for the role you’re applying for, make sure you know everything you’ve put down on the page. For each of your most recent roles, think about the activities that are most similar to what you’d be doing in the position you’re applying for, and prepare a few examples you can talk through in detail about what you achieved.

Honesty Really Is the Best Policy

Be open and honest with your recruiter from the beginning. If you have, for example, a very strong preference for in-office over remote work and the client is advertising a role as hybrid, voice it early on rather than hoping it can be resolved later. You may think you’re talking yourself out of a role by setting a very hard floor on the salary you need to move, but if the reality is that you cannot take on a new role for less than that number, there’s no point in going through the process, and we can instead work on finding another role that will fit for you. Conversely, if we believe there is a good chance of getting a higher than advertised salary, we can advocate for that as soon as we put you forward. Telling a recruiter as much as you can about why you want to move, what you need to make it happen and what’s important to you will be beneficial to everyone involved in the recruitment process, at every stage.

When Hiring:

Getting the right candidate for your vacancy presents just as many challengers on the other side of the equation. How can you get the best out of the recruitment process?

Consider What You’re Offering

In an ever changing talent market and an uncertain economy, firms seeking to hire need to give serious thought to the proposition they’re bringing to candidates. Salaries are important, of course, and carefully benchmarking yours against similar roles is crucial, it is key to offer what the market rate is for the role and the candidates worth, rather than basing it upon what the candidate is on and giving them an uplift. Clarity around the complete package early in the process means only candidates who are right for the role will pursue your opportunity.

Working models and flexibility have increasingly proven to be the crucial sticking points for more and more professionals. There is no uniform offering that will guarantee you buy-in from every candidate – some people prefer to work remote, others prefer to be in-office. When looking at multiple similar roles, many candidates are opting for the one that matches their working model preference even when it’s at a lower salary. It may be that you’re in a position to raise the salary but not to alter the working pattern or vice versa, but the key is to consider these factors and be direct and clear about what you can offer right from the beginning to get those candidates your job is the perfect for to engage and commit.

Control the Timescale …

It is always worth repeating because it continues to be true – the number one reason good clients lose good candidates is timing and delays. Nothing will motivate a candidate to take another opportunity like having to wait endlessly for feedback or being put through never-ending extra rounds of interviews. Obviously there are factors here that may not be directly within your control, but wherever possible I would strongly encourage hiring managers to aim to share feedback within 3 days of receiving a CV or conducting an interview, and to hold interviews within 2 weeks of issuing the feedback. Of course with senior roles there is a very necessary multi-interview process, and it helps to tell candidates up front how many stages that will be and how they will be staggered, if the process can be reduced to two or even three stages for senior hires this will help to give the candidate a good experience rather than it being prolonged over four or five stages where you run the risk of losing candidates to competitors or the individual losing interest.

… And Keep Communication Flowing

Hand-in-hand with the timing issue is the need for frequent, open communication. The best way to prevent a candidate falling out of the process if an interview is unavoidably pushed back is to keep in touch with them, letting them know what’s happening and why. Sharing specific positive feedback along the way also makes a big difference – a candidate will feel very differently about a role where they’ve been told “They want to interview you” vs one where they’ve been told “They really liked [X] and [Y] elements of your CV, so they want to interview you”. Remember that you’re also in the process of selling the role and the company to the candidate at the same time as you’re working out if they’re the right fit for you – every communication they receive along the way will form part of how they feel about your firm.

Working With the Right Recruiter

I believe that working with a good recruiter makes a huge difference to your chances of securing a role – and of securing the best candidates. As specialists with real industry knowledge, the Kind team will have a much better understanding of both what a candidate in our space has achieved and wants to go next, and of what a client needs and how the role fits into the larger business.

It’s a competitive market and you need your organisation and the opportunity to be presented in the right way to gain the interest of those passive candidates, your message to the market is key.

With generalist recruiters, a lot of work is happening on simplistic key-work matching – the recruiter will often not have a good idea themselves of which candidates are actually best for the role they’re working on, or what that role is. We do, and we build strong collaborative relationships with clients. That benefits candidates as well and it enables that open, regular communication between all parties that can make such a big difference.

If you’re currently seeking career advancement in Governance, Risk, Compliance, Complaints, Financial Crime or Change & Transformation, get in touch with your team today on 0121 643 2100 or via

Mathew Kind, Director & Co-Founder

Customer First Compliance – Consumer Duty & Vulnerability

In the last few weeks, we’ve seen news of HSBC being fined over £6 million by the FCA for “failures in its treatment of customers who were in arrears or experiencing financial difficulty”. The group informed the regulator in 2018 that they had identified issues with their handling of customers in financial difficulty – specifically that between June 2017 and October 2018 there had been failure to consider the individual circumstance’s of customers who had missed payments.

In some cases they had taken “disproportionate action” against people who were behind on repayment commitments, potentially pushing them into further difficulty. They had also repeatedly failed to conduct the correct affordability assessments when setting up repayment plans with customers in arrears.

Subsequently HSBC has spent £185 million on redress payments, and £94 million on identifying and rectifying the failures. Combined with the fine, we’re looking at an extremely costly issue.

Across the industry recently we’ve seen discussion of Arrears and Borrowers in Financial Difficulty (BiFD) as regulatory focus areas that could indicate where products are not right for customers – raising concerns relating to customer outcomes.

Speaking of which – we’re rapidly approaching the deadline for the first Consumer Duty Board Report required by the FCA. We all have a clear idea of what the regulator are looking to see here – they’ve reiterated on a number of occasions that the key to achieving those positive, right-first-time outcomes is continual re-assessment and improvement. I expect firms who have taken this approach beyond their initial Consumer Duty transformation projects will have little to worry about come July 31st. However, businesses who have treated the new Consumer Duty rules of 2023 as a one-and-done box-ticking exercise are sure to face close scrutiny – even if they consider themselves to be delivering “delivering good outcomes” for their customers.

The FCA will be looking at what firms are doing in relation to MI and outcomes testing – and any business declaring they are already at “platinum standard” could be a red flag. Arguably after only a year in effect, it would be very unlikely for a firm to already be doing everything perfectly at every stage. Instead, it’s going to be important for organisations to present a narrative of an ongoing journey – what gaps they’ve identified, how they’ve addressed them, how the effectiveness of those new measures has been measured, what that data tells them about what else needs to change, etc.

It’s worth noting that the HSBC fine comes under pre-existing rules, but I expect similar issues we see going forward will incur an even stronger response from the FCA. The current Consumer Duty rules thoroughly foreground the expectation for firms to always be prioritising the best possible outcomes for all customers – and in addition to that, we know that the treatment of vulnerable customers has been a regulatory focus in and of itself for the past few years.

A high profile compliance failure that falls foul specifically of outcomes for vulnerable customers would be disastrous – with a risk of large fines, expensive remediation payouts and serious reputational damage in the eyes of the public. It’s a very good sign, I think, that HSBC identified the issue themselves and informed the relevant regulatory – that kind of positive Compliance culture is the exact opposite of the “wait until the FCA steps in” approach that firms must not fall into.

Kind Consultancy is currently assisting a number of Financial Services firms with Consumer Duty and vulnerable customer related needs, including report reviews, thematic monitoring, outcome testing and the supply of interim and contract Consumer Duty SME’s.

For a confidential discussion about your needs and how Kind can help, get in touch today on 0121 643 2100 or

Moving More for Mental Health + Industry News

If you’re a regular visitor to the Kind Consultancy LinkedIn page, you’ve probably already seen that this week is Mental Health Awareness week in the UK and for this year the theme chosen by the Mental Health Foundation is “Moving More for Our Mental Health”. We’ve been highlighting the ways in which members of the Kind team keep themselves moving throughout the week, and discussing the psychological and emotional benefits they experience.

So how does movement link to mental wellbeing?

Scientists believe that exercise can release endorphins, dopamine and serotonin. Endorphins alleviate pain, lower stress and improve mood. Dopamine produces feelings of pleasure, satisfaction and motivation. Serotonin regulates mood and, at normal levels, makes people feel happy, calm and emotionally stable. All three together then, can make a big difference to how we feel and how well we can function.
With mental health there are no instant cure-alls, but regular exercise can both help to recover from periods of low mood, and to act as a preventative against developing stress, depression or anxiety. The UK Chief Medical Officer’s guidelines recommend aiming for at least 2.5 hours per week of moderately intense activity, 75 minutes per week of vigorous activity, or a mixture of both.

How are we moving at work?

At Kind, we have regular monthly challenges that encourage the whole team to move more by either step-count or distance – recent challenges have included hitting 7000 steps every day, or walking/running over 100 miles total across the month.

It’s important to move during the work day and we all make sure to make use of our lunch hour when we’re in the office to get up and move around – we’re very luck with our location in Lichfield to be near parks that are perfect for getting some steps in within a scenic, calming environment. And even within the office, there’s the Kind Library that staff are encouraged to make use of away from their own desks, with books on mindfulness and motivation.

We’ve also had dedicated days to work on our duel mental and physical wellbeing – for example, a team spa day at Hoar Cross Hall where we could invest serious time into both exercise and relaxation and came away feeling restored and clear-headed.

How are we moving throughout the week?

Already this week we’ve checked in with Selena about her morning runs and lunchtime walks, and I’ve talked about my hiking and running. Other members of the team find other ways to move regularly –

Shai Cassidy: “I make sure to work out every day, incorporating both cardio and strength exercises into my routine. Lately, I’ve been consistent with this habit and have seen a great improvement in my mental well-being, even if it’s just a short walk for 45 minutes. This time allows me to focus on myself and recharge.”

Lynsey Moore: “In my downtime, I love spending time outdoors, in particular at the stables with my daughter and her pony Lulu, which I find both calming and uplifting”

Mathew Kind: “My main focus for keeping a clear head and dealing with the day to day challenges and stresses of running a business is through attending the Gym”

How can you move more?

If you feel like you’re not moving enough and want to tap in to the mental health benefits of regular movement, it’s best to start small and then scale up. A great first step is to start walking as part of your daily routine – if you live within a reasonable distance of where you normally go to work or somewhere you regularly shop, but you normally drive or take public transport, try walking one of those trips instead.

Once you’re walking more, think about what type of movement you’d like to do more of. Maybe working on your mental health is the motivation you need to join a gym, where you can try a wide variety of different exercises within one convenient, fully-equipped space. If you prefer to be outdoors and you find nature relaxing you could look into TCV’s Green Gym programme which combines outdoor activity with conservation. Or maybe you’ve never run before and want a gradated approach to taking it up – try the NHS Couch to 5K Programme.

Find out more about the links between movement and mental health, and get tips and resources on how to start moving more at the Mental Health Foundation website – – and look out for more posts from us across the rest of this Mental Health Awareness Week sharing how other Consultancy team members are moving.

Industry News Overview

Two recent headlines that are worth knowing about –

  1. Financial Ombudsman Service Issues Update on Car Finance Commission Complaints

Regular followers will know we’ve been closely following the Car Finance Discretionary Commission Arrangements Complaints situation (see previous posts on that here and here) and last week the Financial Ombudsman Service published an update, stating that it’s important that consumers understand their plans and that the industry understands their expectations.

The Ombudsman currently have approximately 20,000 open complaints relating to car finance commission. They are awaiting a Court of Appeal hearing on 3 complaint cases and a separate judicial review of an already-made Ombudsman decision on another complaint. The outcome of these could impact the regulator’s approach going forward for similar cases.

Elsewhere, we are still in the midst of the FCA freeze on final responses for DCA complaint – and we won’t know more about their review of the historical use of motor finance discretionary commission arrangements until September.

In light of those two major roadblocks, the Ombudsman wants to make it clear they will continue to accept and investigate complaints as far as they can.

You can read that update in full here and find their information for customers and for financial businesses, including details on what they expect firms to send them when they receive a DCA complaint.

2.      New ONS Stats Show Wages Rising and Vacancies Falling

New data from the Office of National Statistics shows wages rising by 6% between January and March this year – or 2.4% after taking inflation into account. They also show the number of vacancies in the UK dropping by 26,000 – not a gigantic drop, and the number of vacancies is still above pre-pandemic levels.

What are the knock-on implications of these shifts? On the one hand it suggests we might see candidates over the coming months seeking slightly higher starting salaries, but on the other it suggests that employers may have more candidates to choose from for each role. The effects of these slowly developing rises and falls are not always immediately apparent though, and it will be interesting to see how those measures move across the rest of the year.

For more detail, dig in on the full ONS report on Vacancies and Jobs for May 2024 here.

– Catherine Tieley

5 Things You Need to Know About the Financial Ombudsman Service’s New Business Plan

Around this time last month, my colleague Shai Cassidy took you through everything you need to know about the 24/25 FCA Business Plan. Now, their peers at the Financial Ombudsman Service have published their own plans for the next 12 months – and we’re here to give you the 5 takeaway headlines you need to be aware of.

1. The number of complaints keeps on rising…

When consulting on their 24/25 plans back in December of 2023, the Ombudsman forecast that they would receive 181,300 complaints. After considering input from both the industry and consumer groups, the final plan revises that up significantly to 210,000. There are a mix of factors behind that uplift, with the Ombudsman budget citing the ongoing rise in frauds and scams, cost-of-living pressures spurring increased unaffordable lending complaints and media-coverage leading to a rise in complaints about account closures. But one issue looks bigger than any of those –

2. … especially in Motor Finance…

Complaints about Motor Finance Commission have more than doubled from the consultation stage to the final budget, with the Ombudsman’s expectation shooting up from 6,200 to 13,900. That’s a huge increase, and it does not include Discretionary Commission Arrangement complaints that are expected after the FCA’s pause ends. We’ve written about the DCA Situation before [click here for an overview] and this confirms that it’s going to be one of the biggest stories in the Complaints space this year, if not the biggest.

3. … but those complaints should be resolved faster than ever…

In the 22/23 financial year, the Ombudsman’s average timeframe for case resolution was almost five months. By Q4 of 23/24, that had come down to just under 3 months. Utilising a combination of increased headcount and improved efficiency, they aim to resolve 17% more complaints than they did last year. That’s an admirable goal and it will be interesting to see if they can hit that target – and how much more resource they will need to do so.

That surge in complaints won’t just affect the Ombudsman – the industry should think about the potential impact on their internal Complaints teams, whether their firms have the resource and knowledge to handle a surge in the number of complaints and to navigate their subsequent interactions with the Financial Ombudsman Service where those complaints are escalated.

4. … even though the Ombudsman is reducing its fees.

One of the hottest topics at the time of the Consultation, the Ombudsman has followed through on the plan to reduce case fees, with the cost per case dropping from £750 to £650. There’s also a reduction in their other primary funding source, the Compulsory Jurisdiction and Voluntary Jurisdiction levies paid by all FCA regulated businesses that fall under Ombudsman purview. In 23/24, those levies brought in a total of just over £110 million – this year they’ve budgeted for a £40 million reduction.

5. There are no details on possible CMC charges.

The other major conversation surrounding the Consultation last year focussed on CMCs. (See our previous article on this for some background on the CMC Charge situation) The consultation included questions around potentially charging “professional representatives” for lodging complaints with the organisation. The published 24/25 Plans and Budget document does not reveal the outcome of this – the Consultation Feedback section of the document reproduces the relevant questions but simply says that “Feedback on these questions will be included in a separate publication during the first quarter of 2024/25.” The wording of these queries suggests that the Ombudsman wants to strongly discourage firms from passing charges on to the consumers complaining. How successful they are could substantially change the CMC landscape and in term the number of complaints that come to the Ombudsman in the future. But for now, we just don’t know, leaving one of the biggest questions we had going into this Plan unanswered.

It’s looking like a very busy year in the Complaints space, and I would recommend all Financial Services organisations be prepared. Providing experienced, knowledgeable Complaints talent to firms is a core part of our work here at Kind Consultancy, we are able to deliver a Managed Service for volume Complaints projects, as well as smaller numbers on site, hybrid and remotely.  To find out more and have a confidential discussion about your organisation’s Complaints needs, get in touch on 0121 643 2100 or


In Kind news, last week we took a day out to review our success in Q4, strategize and share ideas about what we want to achieve and how over the next 12 months, and celebrate the hard work the whole team put in (see photos here)

And in case you missed it, on Monday for Earth Day our own Catherine Tieley shared some of the ways she’s trying to preserve the environment and live more sustainably this year, at home and in the office – click here to see the video, with some tips you might not have thought of before.

Keep following Kind Consultancy on LinkedIn for all of our analysis of industry news and to see all of our new opportunities first. If you have a friend or colleague you think would like this newsletter, we’d really appreciate it if you recommended us to them and shared the sign up link –

Consumer Duty: The Closed Book Deadline and Beyond

The messaging from the FCA has been consistent from the start – Consumer Duty is not a “one and done” box to tick, it’s ongoing, it should be part of the fabric of all customer-facing work a Financial Services trim does. From last July, there has been one exemption – closed book products, with the consumer duty rules and principles not needing to be in effect until July 31st 2024.

For the purpose of Consumer Duty, closed products are defined as products which were “sold before the 31st of July 2023, but have not been marketed or sold to new customers since”. The relative recency of that date means a lot of products fall under that definition, with many people using a credit card or savings account for a long time that is no longer offered to new customers without even necessarily being aware of the fact that this is considered a closed product. But the industry definitely needs to be aware of it and the steps that now need to be taken in relation to such products.

In a speech last week the FCA’s Executive Director of Consumers and Competition, Sheldon Mills, commended the Financial Services industry as a whole for the work that had been done in relation to Consumer Duty, saying that “many firms have already made great progress … offering the right products and services to the right customers; eradicating jargon and moving clients to less bespoke and cheaper options”. However, he also highlighted that there were some firms who were not being pro-active and appeared to be waiting to see if the FCA will intervene before they’re willing to address an issue.

Ideally, every regulated Financial Services firm in the UK will already have or in the process of embedding the Consumer Duty rules and their cross cutting approach to fair value throughout all aspects of the organisation. They may even have already revised their closed products in line with open ones, to maintain uniform approaches and policies. But clearly some organisations are not getting ahead of the regulatory requirements. Closed products may rely on complex old systems and legacy data, potentially needing even more work than some open products to bring them in line with the new rules.

In his speech, Mills highlighted potential issues with closed book products including gaps in monitoring data, the difficulty in establishing ‘fair value’ from older products designed under different circumstances and the challenges presented by engaging customers who may have fallen out of contact and are left paying for products they no longer need or want.

Kind Consultancy are well positioned to help,  having assisted multiple organisations across many different sectors within Financial Services with their initial consumer duty rollouts, from gap analysis to implementation, post-deadline assessment to training and embedding of the new duty.  Our Advisory Consultants can shepherd your closed book operations into compliance, acting as a ‘Critical Friend’ who can assess already completed consumer duty work to provide regulatory assurance – giving you peace of mind and helping to avoid any regulatory challenges.

For a confidential discussion of your needs, contact us on 0121 643 2100 or

For more on Consumer Duty, read Kind’s Selena Tye on the next steps firms should consider after analysing their current processes. 

DCA: Discretionary Commission Arrangements FAQ

Following the recent announcement from the FCA in relation to DCAs (Discretionary Commission Arrangements) and ahead of tomorrow’s ‘Temporary changes to handling rules for motor finance’ Webinar, Kind’s Selena Tye thought the following Frequently Asked Questions may come in handy.

Q: Our firm never did DCA’s, therefore we do not need to act, do we?

A: Firms need to be mindful that the scope of work may go further than just DCA’s, therefore think about any other arrangements that you have in place.  To head off unnecessary contact from customers and others in relation to DCA, you may want to make a statement in your website making it clear that your firm did not offer these.

Q: We know we have a problem with DCA, but we don’t know where to start?

A: A great start would be to:

  • Identify your timeline – when were DCA’s offered and for how long?
  • Identify your customers that are impacted.
  • Identify what your financial exposure could be, based upon recent FOS decisions.
  • Identify your resource and additional requirements.
  • Identify how you will engage do you keep the regulator informed.

Q: What if we are unable access data or the data quality is variable/not reliable

A: You need to quickly establish what you can do and what you are unable to do, create a methodology which enables you to proceed with confidence.

Q: How do we identify customers with BAU complaints who fall within the DCA population?

A: It is important that first line staff are fully trained on customer outcomes and can identify those that are affected.  You might want to think about a soft hand off process where these customers can be transferred to a specialist team to help further.

Q: With the timescales given to us by the regulator, normal business pressures and to give this the attention that’s needed, are there any quick wins that we can use?

A: Look back at previous projects that have impacted on your customers base, specifically around complaints and commission payments to see if there are any adaptable processes or metrices that you can use.

What about your current MI, is there anything that you can take from there to help with identification of customer cohorts.

Are you able to flex your current teams to accommodate increased work.  Setting up a project team to support will enable ring fenced specialist resourcing.

Q: How do we know if we are doing this right?

A: There will be support from internal compliance and audit teams who can assist with oversight and guidance over regulatory expectations. Think about reaching for external help to validate your internal findings and provide expert assistance.

Q: We need to engage with the regulator, how are we best to approach this.

A: Think about your PRIN 11 obligations and if you must make a notification, make sure you have a plan in place for rectification purposes.

Kind Consultancy’s 2023 Year in Review

One of the great things about working at Kind is that we never really have a huge amount of downtime. It’s never quiet, and never boring. The downside of keeping up that year-round momentum is that it can be tricky to remember to take a step back and look at what we’ve achieved – and we achieved a lot this year.

Kind Consultancy has steadily grown every year since I created the company alongside Lynsey Moore, but this year was particularly explosive – we took on 2 new members of staff, bolstering our capacity to keep up with client demand. This has also allowed us to add a new specialist Change & Transformation team, led by Rebecca Williams who is a veteran of Change recruitment. We’ve worked on Change roles for many years now, but being able to direct our clients to a true specialist has allowed us to expand that offering. Rebecca’s C&T focus also gives all involved peace of mind that they’ll get the same level of outstanding service and top-tier candidates that they trust Kind to deliver elsewhere.

We’ve also expanded our pre-existing ways of working – Interim recruitment is a huge part of what we do now, and we’ve continued to grow the Kind Agile Solutions bench, adding more and more specialist contractors who we know have the skills and experience our client-base needs and deserves. This year saw us reaching a new record for the most contractors we’ve had out on placement at the same time, and I wanted to thank Selena Tye for the work she does overseeing Agile Solutions this year, alongside Laura Kind who has continued to ensure all our KAS contractors have their documentation up to date and can be deployed as soon as a relevant need comes in.

This has been our most successful year on record, and that’s thanks to the hard work of the entire Consultancy team. But I didn’t want to just celebrate the big revenue and placement numbers we’ve achieved – though I am very proud of them. I’m also proud that Kind is an organisation that gives back. We think a lot here about our impact on the local community and the wider world – with that in mind I wanted to highlight our work with Future Forest and our annual winter charity drive.

This year we chose to support our local foodbank here in Lichfield, and I was very pleased that we were able to deliver several large boxes containing a wide variety of food, other essentials, and plenty of Christmas treats. Our partnership with Future Forest is an ongoing programme where a tree is planted for every placement we make. Future Forest specifically works in locations in the UK where trees are needed to foster a liveable environment for local wildlife, as well as helping to reduce carbon in the atmosphere. So far, we’re on track to have planted 132 trees by the end of 2023, and it always feels good at the end of a month to look at the placements we’ve made and know that each of those people is also playing a part in helping to care for the environment.

With all this growth and the variety of projects we’re engaging in, we felt this year was the time to refresh the Kind Consultancy branding and build an all-new website. Launched at the beginning of this month, we’re very pleased that Kind has a professional, easy to use and eye-catching web presence that we feel now matches the level of work that we deliver. If you’ve not already taken a look around the rest of the site, have a click around – make sure you check out the video on the Kind Agile Solutions page breaking down why it’s not your average interim recruitment service, and catch up on all of this year’s articles and columns produced by the Kind team elsewhere in the News section. If you missed the announcement that we’re finalists for Lichfield Small Business of the Year award, you can find out about that too.

2023 has also seen us recognised by Hyer’s “The People’s Platform” award highlighting firms with exceptional company culture, and Kind made the cut of just 100 recruitment companies selected from over 1000 entrants. We’ve continued to drive that culture by achieving the Bronze level from Thrive, a WMCA programme that certifies companies that go above and beyond for their employee’s physical and mental health and wellbeing.

The timing has lined up nicely to launch a new site , be awarded as an outstanding employer and shout about how great this year has been at Kind, because we’re not going to slow down any time soon. The number and range of client organisations we’re working with is greater than ever, and we’re currently on the look out for more experienced recruitment consultants to join us in 2024.

It wouldn’t really be accurate to say that we’re “winding down” for the year – everyone on the team is busy and I know we’ll all keep the pace up right until we finish for the Christmas break on the 22nd. I want to once again thank everyone at Kind for their contributions to a truly spectacular year, alongside all of our clients and candidates that make this possible. We’ll be back in the office on January 2nd, and I look forward to seeing where we can go next. It feels like we only ever get better at Kind, and from here anything is possible.

Are You Equipped to Tackle APP Fraud Scams?

What is an APP Scam?

Get ready to start hearing a lot more about APP (“Authorised Push Payment”) scams. APP is a type of fraud where someone is tricked into sending a payment to the account of a criminal. The UK government’s policy paper on APP last year said that these scams “have increased both in value and volume, with many individuals suffering significant financial and emotional harm” and UK Finance’s 2022 fraud report showed over £485 million lost to APP by both individuals and businesses.

The Payment Systems Regulator and the Financial Services industry have been working together to reimburse victims of APP for years now. In 2019 they introduced the Contingent Reimbursement Model Code, a voluntary scheme under which payment service providers voluntarily commit to reimbursing people after an APP scam. In theory, this covered around 90% of all affected transactions, but the government and the Payment Systems Regulator (PSR) agreed it wasn’t enough.

The New APP Rules

As of last week, we now know what the next stage of regulation around this issue looks like. The PSR has published a consultation on proposed new rules on reimbursing those who fall victim to these scams, which will be part of a package of changes which will also address reducing the number of APP cases through measures such as expanding the use of “Confirmation of Payee” checks.

The deadline for those rules coming into effect is now set for October 7th 2024, with a final revised set of rules to be published before the end of this year. From that date, the new rules will cover all transactions carried out using Faster Payments where the payer has either been misled about who they are transferring money to or misled about the purpose of the transfer – with exceptions for cases involving civil disputes, international payments and any payment made for unlawful purposes.

The provider of the victim’s payment services will be required to reimburse the person who has lost money within 5 days of the fraud being reported, and they will then seek to reclaim 50% of that cost from the payment provider of the fraudster.

Getting Rule-Change Ready

Organisations now have essentially one year to get everything in place to meet these new requirements. Failure to do so will incur financial penalties from the PSR, and there is also a substantial risk of an organisation’s reputation amongst customers being damaged if they’re seen as not dealing with fraud fairly and quickly.

Changes will need to be made to systems and policies, ensuring that the right result can be arrived at quickly if a customer is defrauded. APP is thought to be significantly underreported – something that’s likely to change if customers know a refund is guaranteed. The new rules will allow a customer to raise a claim as long as 13 months after the incident, so organisations should therefore expect to see a fairly immediate spike in these reports, which will need turning around in that tight 5-day deadline. It seems likely that we’re going to see very large-scale redress projects needed very swiftly once the rules are in effect.

Preparation and Prevention

Many businesses are already working to make APP scams harder to commit in the first place, but the new rules will definitely motivate more organisations to put time and resources into this. Investing in prevention will be crucial to reducing the overall number of APP fraud and in turn, lessening both the financial loss and the workload for remediation teams.

Payment providers will need to re-assess and re-think how they can build checks into the user interface for online banking and mobile apps, as well as informing customers about how this type of fraud is committed and giving people the tools to help them make legitimate transfers with confidence whilst spotting any potentially fraudulent requests.

How Can Kind Help?

So how can Kind Consultancy help you get ready? We work with a number of regulatory compliance experts who can help your organisation to create and implement the frameworks you need, including:

  • Creating and delivering training to both management and frontline staff
  • Policy and process review
  • Gap analysis
  • Enhancing your firm’s existing due diligence
  • Designing the new reimbursement framework

Every firm is different, and our industry-best subject-matter-experts in Kind Agile Solutions will tailor an approach that suits the specific size, scope and needs of your business.


Kind Agile Solutions is our interim talent service, built on a pre-screened bench of contractors who we know and trust to deliver exceptional work to our clients. This means we’re also uniquely positioned to assist with any volume resource needs relating to redress projects, with the ability to have skilled contractors with relevant experience on-site faster than any of our competitors.

We expect there to be a high demand for consultants working on APP fraud requirement readiness, so we recommend contacting us on 0121 643 2100 or soon for a confidential discussion about your needs.

[This article originally appeared on Kind Consultancy’s LinkedIn on October 2nd, 2023]

Checking In On Fair Value Preparations

Earlier this month the FCA published their findings from a review of Fair Value frameworks. Fair Value is one of the 4 outcomes on which firms will be assessed under Consumer Duty when it comes into effect in July. To help establish the regulator’s expectations, the FCA is providing feedback based on organisations’ proposals. For this report, they looked at the Fair Value Assessment Frameworks of 14 firms, with the aim of both highlighting good practice and areas of improvement to provide clear examples.

What kind of evidence does the FCA want to see to prove that your business offers customers Fair Value? The Fair Value rules within Consumer Duty focus on ensuring that the price a customer pays for a product or service provides “reasonable value” relative to the overall benefits. The regulator will want to see clear proof that organisations have considered the nature of their products and services, any limitations of the product or service and the expected total price customers will pay across the lifetime of the product.

For this review, the FCA assessed the Fair Value Assessment Frameworks on their understanding of Fair Value rules, how costs and benefits to customers (including non-financial costs and benefits) are being assessed, how the firm has included wider contextual factors in their assessments of value, what approach has been used to assess the range of possible consumer outcomes (including outcomes for vulnerable customers) and how a firm is using data to monitor and measure fair value.
The good practice sections for each of these five assessment factors are encouraging reading, suggesting many firms have a good understanding of what they need to do and are on the way to achieving it. For example, the report says that the majority of frameworks have clear principles for how they will apply the concept of fair value, most frameworks have a reasonable view of how to assess consumer benefit, including non-monetary factors, and many firms are considering the interplay between Fair Value and the other elements of Consumer Duty.

I would recommend anyone working on Consumer Duty preparations read the full report, but I wanted to highlight some of the key Areas for Improvement that the FCA names.

First, looking at the “understanding fair value” assessment, they raised a concern that some firms “planned to rely on high-level or unevidenced arguments that their business models or ethos are inherently fair value”. This is something we’ve talked about in previous Consumer Duty articles – almost everyone working in Financial Services believes they’re putting out good products for their customers. It’s going to be crucial to get past that kind of belief in the “self-evident” and to provide substantial evidence that your products are providing fair value. The FCA is also concerned that some firms have “not given sufficient thought to the distinction between manufacturers and distributors in PRIN 2A.4”. Whether a firm is a manufacturer, a co-manufacturer or a distributor makes a substantial difference to how they should assess the costs and benefits of their services.

Next, within the “assessing value” findings, they flagged that some firms who operated across multiple markets were using a single generalised template for assessing Fair Value. Any business with a wide range of products across different market sectors is going to need to think about how they adapt their approach for each of those sectors. The FCA also mentioned that some firms had failed to make any reference to their profit margins on products and services and pointed out that this is “likely to be a relevant factor in assessing [a product’s] fair value.”. Finally, on assessing value, they were concerned that some firms were not considering non-financial costs and benefits – for example, quality of product and level of consumer service on the benefit side and the time taken to decide about a product and the effort needed to make an amendment or cancellation on the cost side. It’s going to be important to think about those factors that can’t be reduced to numbers on a page, providing a holistic view of how your organisation is providing Fair Value.

Under the “considering contextual factors” section, the FCA were alarmed that some firms were simply not giving substantial consideration to broader contextual factors and their impact on Fair Value. Again, it’s not going to be enough to say a product provides positive financial value, organisations are going to need to look beyond that – especially for larger firms and complex offerings. There was also concern that some firms were not considering what information they needed from other firms in their distribution chain, which will be vital to assessing fair value of any product that involves third parties.

In the fourth section, “assessing differential outcomes”, they noted that some of the information being presented in frameworks had a tendency to “rely on average outcomes rather than analysis to understand the full distribution of outcomes”. Remember that averages are likely to mask outliers and what the report calls “pockets of poor value” – just because you have an average positive outcome, your assessment needs to consider the value being provided to customers who do not have the normal positive experience with your product.

Finally, under the “data and governance” findings, the FCA raises concerns that some firms have not identified how they plan to monitor Fair Value, what data they want to use and how they will address data gaps. A lack of proper data will lead to vague, “high-level” cases being made which, again, will not be enough. A related issue is firms failing to consider the limitations of the data they were using to evidence Fair Value, making it unclear how decision-makers would be able to critically review this evidence. There was also a point raised about firms using market-level benchmarks and presenting their case for Fair Value in terms of relative comparisons – this can hide value issues which are prevalent across the wider market. Finally, where firms are using “traffic light” or points-based approaches in their Fair Value Frameworks, there needs to be substantial critical analysis around those scores and ratings – firms need to examine how thresholds between different ratings and points are drawn and whether sufficiently detailed information is being provided to review and challenge the assessment of Fair Value.
It’s a lot to consider, but there is still time to get your organisation ready before the July 31st deadline.

Kind Consultancy recently supported a client through an initial Review of Target Market Fair Value and processes to ensure they were in line with FCA and industry expectations. This included examining the way the firm had assessed their target markets, benchmarking against those in and outside the sector, looking at what was needed to maintain a cycle of continuous improvement, agreeing on what conditions would trigger an urgent out-of-cycle Fair Value review and how senior management were informed in order to provide assurance that their risk tolerance was being kept within the required parameters.

If you are looking for a ‘fresh pair of eyes’ to act as a critical friend, Kind Consultancy work with a number of consultants who are available to provide you who can independently assess the work you have carried out so far and highlight any changes needed in order to be Consumer Duty ready. framework and highlighting any changes needed to be Consumer Duty ready.
For more information, please get in touch on 0121 643 2100 or e-mail for a confidential conversation about your needs.

What Are the 2023 IR35 Rule Changes?

If you’re a contractor in the UK, you’ve probably been paying close attention to discussions about the IR35 rules and have probably read and seen reports of possible IR35 rule changes set to happen in 2023. But what are the rule changes and how will they effect you?

IR35 is not changing in 2023.

In April 2023 the UK government had announced plans to repeal off-payroll rules, which would have moved responsibility for determining if a contract sits inside or outside IR35.

These plans were rolled back shortly after their initial announcement in the September 2022 mini-budget.

There will now be no changes to IR35 rules, and contractors will continue to be bound by the off-payroll rules introduced to the private sector in 2021.

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