Steering Clear: Compliance Essentials in Motor Finance

Explore vital insights into motor finance compliance, regulatory challenges, and operational strategies with the industry expert Nick McDonald, Co-founder and Director of The Compliance Guys and Matthew Westway, the CEO and Co-founder of Voyc. 

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If you are in motor finance and care about keeping your business compliant this podcast will help you get insights into:

  • Navigating the Regulatory Maze
    Explore the intricate landscape of motor finance compliance, revealing strategies to navigate regulatory complexities with precision and confidence.
  • Deciphering Commission Disclosures
    Dive deep into the intricate world of commission disclosure, unravelling its implications and strategies for dealers, brokers, and lenders in motor finance.
  • Strategies for Compliance Excellence
    Uncover essential tactics for identifying and fortifying operational compliance frameworks, ensuring resilience against regulatory challenges in motor finance.
  • Allocation of Liability in Focus
    Analyse the intricate web of liabilities among dealers, brokers, and lenders, shedding light on the complexities of DCA arrangements and their implications.
  • Forecasting Regulatory Trends in Motor Finance
    Anticipate forthcoming regulatory challenges and priorities, gaining insights into the future landscape of motor finance compliance and industry dynamics.
  • Optimising Business through Journey Mapping
    Embark on a journey of business enhancement through meticulous customer journey mapping, harnessing strategies to elevate compliance standards and drive profitability in motor finance.

Right, welcome everyone to another episode of the Voyc podcast where we’re going to tackle complexities of motor finance companies. Today we’re joined by Nick McDonald, one of the co-founders and Directors of The Compliance Guys. A specialised and truly unique compliance agency that helps firms from getting authorised, to how best to offer finance to their customers, amongst many more things that Nick will be sure to share with us today. Nick has a long career in motor finance and compliance and will help us dive into the impact of some of the recent regulatory changes and compliance challenges faced by motor finance firms today. So, welcome Nick! Welcome to the show! Thanks Matthew, nice to join you it’s like a busman’s holiday joining a podcast like this, as I talk about motor finance compliance all day, but you know hopefully it benefits people. Fantastic, definitely Nick! So, Nick today what we’re going to talk about is Consumer Duty implementation and its effects on lenders and brokers, and looking at how fast the industry is moving and adapting to the Consumer Duty. Secondly, we’re going to touch on, you know, from adjusting operations to safeguarding vulnerable customers what are some of the key compliance challenges. Thirdly we ‘re going to touch on some real world examples that I want to ask you to share and some red flags that companies should look out for when when it comes to the Consumer Duty. Then we’re going to look onto the future of where we think the motor finance industry is heading and what some businesses can do today to make sure that they’re ahead when the time arises. For all those that are streaming in, I’m Matthew Westaway, One of the co-founders and the CEO of Voyc. We’re a call compliance monitoring platform for motor finance companies and I’ll be your host today so fasten your seatbelts as Nick gives us a tour through some of the compliance essentials in the motor finance sector on this Voyc podcast. So first of all, Nick first thing I wanted to look into is how do you believe recent regulatory changes have impacted motor finance brokers and lenders in the UK? well I think it’s the first thing to say is that the motor finance sector is probably more complex than people realised to start with what I mean by that is in a lot of financial services the product provider, in this case the lender, is often dealing directly with the end user, the consumer, or if you take mortgages and insurance they’re often going through a broker. In the motor finance sector, you’ve almost always got a dealer in there. Well by nature someone supplying the vehicle but that’s often the point of entry they then may also be going through a broker before getting to a lender or dealing directly with a lender. So, when it comes to Consumer Duty for instance, which is the obvious most recent change there’s a lot of complexity in there as to who governs who, who’s looking at Consumer Duty, sharing outcomes, and many other things. So I think that’s been you know obviously Consumer Duty is the big change, but the big challenge has been how everyone deals with each other to get the right outcomes for customers, and who’s responsible for it, and I think there’s been some big challenges around that in particular. That’s very interesting. So what I’m hearing is there’s essentially three stakeholders instead of two. Traditional brokers and lenders, but now we also have these dealers, and there’s challenges as to whose responsibilities lie where and, where have you seen overlap there? What are some of the examples where you commonly see “it’s not my role but it’s their role” type of situation? Well I think quite rightly when it came to like the lead up to Consumer Duty, doesn’t it seem a long way away by the way, now I remember getting to July last year and thinking wow this has taken so long to come around and now we’re nearly a year down the line as we were leading up to April, certainly when the lenders had to put out their price and value assessments, there was a lot of secrecy I think around who was going to do what, and we did an exercise of collating all the different documents from all the different lenders to try and you know see the commonalities and that was a really complex piece of work so it was clear that everyone had done their own work on it I think what that means is that not only had they not shared the information with each other as lenders to get a homogenised kind of approach, but they also maybe not engaged the brokers or the dealers alongside, and that’s the same as the brokers the brokers may have got some information from the lenders, but maybe not from the dealers, and dealers quite frankly didn’t do much about it you know, I’m talking the independent dealers we deal with you know the main dealer groups, so what you had probably as soon as Consumer Duty was implemented, everyone had their own approach, everyone had, in the large taken it seriously, done their assessments, but they hadn’t really worked out how to share data and how that was gonna work with each other I think everyone is still now going through that process going well we understand maybe what our Consumer Duty outcomes should be, but does that actually align with the other partners we deal with. How quickly are they making changes at the moment? I think people are taking it seriously is the first thing to say and just like the FCA said it’s not a ‘once and forgotten’ and quite rightly so. I think it’s still going to be an evolution I think when we come to this you know the anniversary let’s say of Consumer Duty and everyone should know if they don’t that everyone needs a board report on Consumer Duty outcomes and data and all that good stuff I think there’s gonna be a lot more outcomes of that and we’ll see the holes in like kind of well, how have you shared this information have you understood what lenders want if you’re a broker or a dealer, as a lender how have you understood how your brokers or dealers have done the implementation so I think there’s been some work on that I think a lot more will be to come after the first anniversary If you look at the brokers, dealers and lenders, who’s done the most work so far and where do you think there’s room for work to be done? I think you need to speak about each of them because I think everyone’s done some work you know the lenders quite clearly took it very very seriously you know everyone had their price and value assessments in on time and some of them were absolutely excellent some were a bit more bare bones and you know that was shared in a in a really good way but I don’t think the lenders on the whole have done a great deal of making sure that the brokers and dealers have done absolutely everything they should. What we are seeing now, actually though, is lenders pushing brokers certainly to do a lot more oversight of their dealers where it’s that kind of dealer introduce the broker introduce the lender arrangement. So, for instance, I know some of the brokers are now being asked to get copies of information notices that the dealers are given. Brokers, we found kind of left it a little bit late last year. Some of them, not the biggest ones but you know some of the medium size brokers, there’s a lot of them, some of them came to us and said ‘can we do this exercise’ and we only had maybe three or four months left untill the deadline. They took it very seriously at that point at least and you know we have conversations all the time about Consumer Duty outcomes which is really good and certainly in our market which is the independent dealers mostly, the dealers want to follow the lead of what the broker or the lender says maybe not even what we say so we’re continuing now engaging with lenders and brokers to go ‘what more do you want?’ rather than just what we think the FCA want and the dealers are starting to come round but ultimately it all gets led by what the lenders do, and if the lenders say we need everything to be perfect the brokers and the dealers will follow but they probably won’t always do off their own back. Do you think it’s, if we look at the credit broker versus a dealer and the amount of money that is made off of a sale my understanding is a dealer makes far more for a sale on a car than the credit broker But the responsibility then lies more on the credit broker to make sure that customer was given the right outcome Do you think that’s fair? Do you think it should balance more towards the dealer? I think there’s two sides of looking at this if you look at the whole transaction value so you look at the actual margin on the vehicle any associate services any unregulated products and then the finance commission, yes, the dealer makes more money. If you look at just the finance commission it may well be the broker and in the past the FCA would have said well it’s the person making the commission or making the interest on the loan that’s the most important party. But what Consumer Duty does of course is tie in everything that’s unrelated to not only that sale but other sales but I’m not sure I’m allowed to swear so say the proverbial faeces flows downwards that’s what they say isn’t it it rolls downhill yeah and I think if you then look at things like the differential commission arrangements that’s being targeted absolutely the lenders to start with to roll down and you know we’re probably jumping the gun on to something else we might talk about but, if the lender’s going take the first brunt the broker’s going to take the second brunt the dealer’s gonna take the last brunt and ultimately you know the FCA will always deal with the biggest firms they’ll always come down the hardest on the biggest firms because they’re the ones who can pay the fines I’m afraid. When they come down on the biggest firms are you seeing certain dealers sort of getting treated you know more because of their size compared to every dealers? so are certain dealers on the – No I mean, that does happen we know with the big franchise groups you know there’s some I won’t mention name there’s been you know some investigations that we see into big dealer groups but what we do see, we deal with some of the smallest firms offering finance, is that the FCA are asking for more and more requests more and more reports newly authorised firms especially coming under a lot more scrutiny whereas I think under Consumer duty for instance the FCA are expecting that the other stakeholders the lenders and the brokers are you know taking that oversight and encouraging the dealers to do more where you know they’re still getting more reports to do but probably aren’t getting the same level of scrutiny that new firms would be. Okay, fantastic. So, it sounds like you’ll have an easier time being a dealership than a credit broker in the Consumer Duty. From a compliance point of view, yeah and that’s probably right although we’re talking that you know the dealer may make more money their main business is not financial services that is secondary to make an introduction. What dealers do need to do and should do, is take very seriously that introduction because customer, although it’s not an advised sale, the customers do listen to what they would feel is a recommendation. That could be who they’re introducing them to, what product they’re introducing them to, you know and they need to take that, even if it’s a small part of the business, they need to take that small part very seriously to make sure the customer is getting the right outcomes. When you see outcomes going wrong, it takes me to the second point around compliance challenges, where in the journey do you see those outcomes going wrong? At what point does the customer fall under detriment? You might find this surprising but from a dealer point of view I think it’s whether they’ve picked the right partners in the first place we still see and hear instances where smaller car dealers will say I use a broker and, you know, the great thing with brokers often is they’ll have a panel of lenders the dealer hasn’t got to worry about you know who’s the right lender for the customer a lot of that works still in the background very well by the broker but then they’ll say oh but I still use one single lender first before the broker and we’ll go okay why is that? are they offering a better rate? is it a better service, is it faster? and they be like oh no I’ve known the rep for 10 years and they pay me more commission and you’ll say so but the rate must be better for the customer no no the rate’s higher and you’re like that’s not allowed so there’s still a lot of learning to do there and that’s won’t happen everywhere but ultimately the dealer has often chosen who to to deal with not because of the right thing for customers but for the right thing for their business. Just on that point of it not being allowed, to just elaborate on on that because what I’m hearing now with this discretionary commission essentially when they banned it it was almost like it was better to not ban it because then you gave the ability to set the commission down to you know closer to the customer it’s counter-intuitive It’s a whole other podcast… but at a high level explain to the viewers just touch on that a bit I think, I won’t give my view but I’ll give the argument the argument is simply that post differential commission agreements being banned overall customers have paid more for finance on average that’s a simple fact and people have data on that so whether the ban is effective is very much up in the air but yeah on an individual basis certainly dealers can’t change the commission that sounds like a good thing but whether it’s saved customers money is a different argument but yeah on the basis of why that’s not allowed it’s simply that you’ve got to be giving the best outcome for the customer and that’s not always the lowest rate by the way it’s not always the lowest APR it could be that a customer really needs a vehicle quickly and therefore the agreement might be slightly more expensive but quicker to set, that’s valid if it’s true it could be that the total amount payable is lower if you take a PCP, the payment might be lower on one but the balloon may be lower and therefore there might not be an equity at the end of the loan so there are you know there are a lot of circumstances to consider but certainly if you’re using one lender at 13.9% APR and you’re sending every customer there the customer’s going to believe that is the best rate that you can offer. if you’ve then got a broker that can do 9.9 but you’re not using them because you can make more commission from the first lender unless you can you know realistically prove that the customer wanted to pay that higher rate for a valid reason, that’s absolutely not giving the right outcome to the customer. How can some firms prove that they’re not doing that? I think the question Matthew is are they being asked to prove that they’re not doing that? and I’m not saying this is widespread but I’m saying we hear enough of it that it certainly goes on and this is where we go back to that point of are the FCA asking for that data directly? no they’re not but where lenders and brokers are aware that that’s happening and I would call on lenders who know that they’re the first string to be checking is that dealer using another broker or using a broker at a lower rate and really should your rate be set higher if you know that dealer is using you first line that should be you know falling foul of avoiding foreseeable harm shouldn’t it. Definitely, you know this is something which maybe exists and something which you know if it doesn’t it would seem quite trivial of a solution but it’s just that the consumer should have two options always and always be presented with two options that, similar when a in a large enterprise buy software, they need multiple quotes. Is that something which would be a way to prove that customers are given you know I think we should be given all quotes I don’t think it’s too difficult with technology now to do that. So, for instance we have technology off the back of some of our compliance systems and the some of the plugins that we use often say well do you wanna just display the best quote and my argument is well what’s the best quote let’s display all the quotes and the customer can then go well do I want a PCP or an HP you know do I want lowest APR lowest total amount payable lowest payment and then let them see which is which and let them see the detail and I think you know anyone offering finance needs to ensure they have the right level of knowledge and training to be able to explain to those to customers, so that customers can make an informed decision. And Nick when it comes to compliance challenges, so yes we mentioned that it’s the relationships that the dealers have formed often that is the start of it looking at loyalty and working with people that they’ve worked for a very long time, best for them not necessarily best for the customer, what other compliance challenges are you seeing motor finance firms face today? I think, this probably goes for all firms, the biggest difficulty in motor finance has been identifying vulnerabilities I think it’s very easy in some industries where this is what we probably call a slower sale to identify that so if you take a mortgage for instance no one expects a mortgage to be approved in minutes and paid out in an hour so if you were to ask a mortgage broker to go through a detailed analysis of the customer yeah which they often already do with financial information but you know from a checking vulnerability’s point of view and you say I’m gonna do a full assessment it’s gonna take 15 minutes as a percentage of the sale that’s a very small amount of time I think in motor finance what a lot of people are doing, ‘how are we supposed to identify vulnerability?’ and if you take one of the FCA’s measures of, i’ll call it ‘roughly half of the customers may be vulnerable at some point under certain circumstances’ I don’t know of any firms in consumer credit who are measuring anywhere near 50% vulnerability and I’m sure you’ve got some statistics on what you find with your software but I would say even with yours I’m gonna hazard the guess people don’t get to 50% not at all and I think that’s a challenge and I think the other challenge is a mental challenge where people think if I identify vulnerability I can’t give this person a loan or I can’t sell them a car and that’s absolutely not what’s trying to be done but that’s absolutely a challenge in both identifying vulnerabilities and enabling journeys based off you know people’s circumstances. What we see is definitely a you know in the credit broker space the sales agent won’t want to report it because they’re worried they’ll lose out an opportunity so it’s a, you know I think it ties down into the commission that they’re going to get. We, in our software, we log at the moment it’s around 8% of sales calls in a credit broker we see a vulnerability and surprising to a lot of our clients has been the nature of those vulnerabilities. So we see a lot of people saying they are disabled and they need a car that can cater for their extra needs and they can’t go view the car so they need delivery, and for companies to realise that before you know we came along, I don’t think many of them knew what percentage of the customer base was of such a unique needs. I don’t think a lot of them would have understood what vulnerability generally is and I know you’ll have heard me say this before Matthew but I hate the word vulnerability I think it’s the worst choice of word because if I ask you are you vulnerable it’s a really negative word no one wants to be vulnerable and if I ask do you have any specific needs that I might be able to help you with that’s a positive and I think often people need to change the word in order to change the identification of it. Definitely yeah that is a great way to say do you have any sort of you know extra needs or anything else I can do to support you further. The vulnerability term also some clients themselves don’t want to disclose it, so it’s how do you kind of get them to to share without them being worried that it’s going to impact the success of the application. One thing we’re doing so you know you mentioned we do authorisation works we had to help a lot of you know, especially independent motor dealers, get authorised for financing. The FCA you know are now beefing up that well have beefed up that process that the bar of getting authorised is much higher so we do a lot coaching with the applicants you know what they should know and if we ask an applicant what do you think vulnerability is there’s two answers and it’s the same every time one is customer has credit issues or mental health issues and they’re the only two things they think at the outset are vulnerabilities and then when we go through and go what about life events, that someone got divorced even married, had children, had bereavement whatever that might be you know or are they hard of hearing or you know whatever it might be people’s eyes are open to their own vulnerabilities you know and what things may affect them and what we’re finding is training and coaching and understanding of vulnerability really opens up a lot. It doesn’t identify stuff in the journey by the way which is why we’re such a big fan of your technology but it does open up the minds of the people running the the organisations to why they should be helping and not just seeing it as an FCA tick box. Definitely, one way I like to think about it the definition of, if we use the word vulnerability, is can that person make a decision in three ways can they make the decision unaided can they remember it, can they afford it and those are the three criteria which we find particularly useful to claim from a training perspective how to think about identifying vulnerabilities can they make a decision unaided remember it and afford it. Nick, when it comes to some examples of sort of catastrophes or significant consequences for firms have you seen any recently and could you you know share an example with our viewers? I’m not sure about catastrophes but certainly the burden I think of compliance can almost feel like a catastrophe I suppose you could argue that you know the DCA complaints or the gap insurance stuff that’s going on are certainly some significant events but I think more than anything people just need to be prepared for compliance events you know compliance is often seen as an afterthought and something that can be you know either done once and forgotten or it’s just a tick along part but you know when a compliance event comes on whether that’s the FCA throwing a spanner in the works as I call it or a data breach or you know whatever that might be, people need to be prepared for it and my big best advice to people is just you do that planning ready for the worst because compliance can’t be an afterthought I’m afraid because it will if profitability is the only thing that’s important to you compliance also has to be important because it will kill your profitability, when an event comes along. Prevention is definitely better than cure definitely I couldn’t resist Nick one thing which I saw earlier today I met a company they’ve put together 100 agents getting ready to jump on the commission disclosure and they used to work in the PPI space and they hired 100 people, they’ve got all the outbound phone systems ready and they’re looking forward to the end of the year to start dialling and what are your thoughts on that? I think they’re vultures is the top of it I think there was some harm to some customers you know there were certainly circumstances where some customers were charged more than they should have been because of their lack of understanding let’s say that’s a problem but you know in general most dealers didn’t do that claims companies will always do what the regulator allows them to do and in a good way you know the regulator has a love hate relationship with claims management companies they don’t like the fact that they you know take money out of customers pockets they do like the way that that helps them to deliver the message of you know any perceived wrong doing and help customers to get recompense for it but you know it was going to happen and if it wasn’t that it was the diesel mission scam if it wasn’t that it was the PCPs it’s always going to be something and that just goes back to my last point of you’ve got to be prepared and have the right processes in place to deal with these things. That brings me to the next point so you mentioned prevention, be prepared, what warning signs or sort of cracks would you recommend companies look out for in their internal operations and their kind of governance frameworks at the moment that are signs that they’re not prepared? I think if we take that point in isolation complaints policy and complaints processes are two things. So, the FCA obviously straight away when the DCA announcement came out you need to change your complaints process to allow for the cooling off period let’s call it or the difference between a DCA complaint and not a DCA complaint and I don’t think they actually understood the whole impact for that cause it was a bigger impact on us than the actual firms for instance the firms just had to change a document we had to change our entire software system to handle the complaints in a different way you know like add a different category add different times scales but you know I think if you’re an individual firm one make sure your complaint policy is robust make sure it’s trained out to anyone who could have customer contact and just be confident in how you’re going to deal with each complaint. We still get calls daily saying I’ve had complaint from either a claims management company or it’s come down from the ombudsman, by a lender or broker what do I do and you know we help people but I always question like why don’t you know what to do you know you really should know how to deal with a complaint in your business time scales we don’t judge people you know we deal with everyone and help everyone but you know the definition of insanity is doing the same thing again and expecting a different result well you’re going to get claims so you know when you’ve dealt with the first one make sure you know what you do with the second one that’s for sure. And in terms of the liabilities like across the dealers brokers and lenders how is it shared specifically with these DCAs? Well the FCA have made it very clear that everyone is responsible for their own complaints so if a dealer or a broker gets a complaint they have to handle it not just fob it off to the lender and the same obviously for the lender however, they’ve also kind of I don’t know if they’ve made it clear with, certainly insinuated, that the lender is the person who put that DCA arrangement into place with the dealer and allowed the customer to borrow at certain rates so they’re gonna get the brunt of it I think the question then is going to be do the lenders under their dealer agreements go down to the dealers or the brokers and and ask for some of that money back? I’m not sure it sounds like cutting off the head of the golden goose to me. It’s very interesting times, what do you foresee with this Lloyds 450 million, I saw they put aside, do you think that’s enough? uh no not if you look at the the value of the PPI claims and what they ended up I can’t remember the figures but I think it was something like people ended up paying out like 3 times what their provisioned for to start with I think, I understand why they’ve done it, and obviously it’s public because they’re PLCs but it kind of almost gives the FCA the green light to give some, you know some recompense to customers the fact that it’s been put aside so it seems almost inevitable that something will come out of it yeah whether we agree or not. It definitely led to the a few more claims management companies being incorporated that’s that’s for sure yeah. Nick when we look at you know, back to sort of the commission piece could you just explain to the viewers initially where was the wrongdoing there? so say a customer does end up paying more than they should have why was that wrong? and and perhaps equate it to another industry and business, if you go buy a pair of shoes from two different retailers the one could charge you more for the shoes why in the car finance sector is it particularly wrong? I’ll tell you first why it was wrong under FCA rules, the boring bit, and then I’ll give you kind of the caveat to that so what the rules state is not that you couldn’t charge an amount above the base rate but if that agreement was in place if it materially affected where you chose to place the business or whether the customer’s decision to proceed or proceed with that product would have been affected by the existence or nature of commissions that’s the fact that was commission there or the fact that they knew that it would be the difference between you know let’s say a base rate and charge outright then you had to disclose that the commission was there and then upon request the amount if asked and that didn’t happen basically the caveat to that is well if you look at one of the false complaints I’m gonna get these numbers wrong but I’m gonna say the base rate was 2.9% is what the dealers base rate with the lender was, and they charged out I think it was 4.9% or 4.99 so let’s just take 4.9 so there was 2% raised rate the argument is that the customer could have got 2.9 the counter argument of that is no one got 2.9 and the lender knew that no one was gonna get 2.9 and if they did the base rate would have been set higher that’s how a lot of these arrangements were made is that the dealer didn’t get 100% of the difference they often got 50 or 75% of the difference so the lender always actually made more than they would have done at 2.9% and so if that arrangement wasn’t there the base rate might have been lower than 4.9 but it would have been higher than 2.9 and the further argument to that is if the dealer wasn’t making as much out of the commission would the price of the car have been more would the customer got as much of a discount would they have got a service plan or you know the deal in its entirety needs to be looked at rather than just the cost of the loan so there’s a lot more to looking at this than just what was the base rate, what was the charge out rate. Wow so there’s also second order effects there as well on that consumer they potentially could – yeah that would be the defence. In terms of the future for the next sort of 12 months ahead how do you see the regulatory landscape evolving and where is the next kind of DCA? oh who knows it’s the middle of March and it feels like 2024 should have finished by now it feels like we’ve had 12 months of regulation changes and things to deal with in you know probably the first two months of the year so, I will answer your question we’re gonna see what the outcome of the gap insurance investigation is gonna be that’s going to come in the next 12 months and who can continue selling it and by the way that will have a knock on effect on all other add ons not just regulated add ons but non-regulated add ons the FCA is already looking at things like warranty and service plans and stuff like that and just to give a bit of background I think although they’re not regulated products because of Consumer Duty, a regulated firm has to also look at its unregulated products and look at them in line with that so that’s why that’s coming under scrutiny. We’ll get the outcome of the DCA complaints and we’ll have the outcome of the first anniversary of Consumer Duty and what people have done and not done and you know if you look at what happened with gap insurance for instance the reason that is come to afore is because certainly post Consumer Duty that the insurers had a responsibility to make sure that there was price and value in those products. the FCA decided there wasn’t and not enough had been changed and they took action. Well if we get past the end of July and the FCA check Board reports, which they will do, and then see there’s not enough actions being taken on other areas we’re going to see the same repeated and this won’t just be DCA from you know up to the start 2021 this may be what’s currently going on with price and value so, it’s going to be a busy 12 months that’s for sure. Nick, in closing if you had one compliance tip for the industry, what would it be? We’ll keep it in line with Consumer Duty we did this with a quite a few brokers and found it very powerful, is map your customer journey start to finish that’s from any touch points in marketing all the way to post sale communications and especially anything in the middle where you’re speaking to customers if you look at the four Consumer Duty areas and the three cross cutting rules and look at each point of your journey you will automatically find your own improvements and what I promise people is you won’t just find improvements for consumers you’ll actually find improvements in profitability and areas that you can you know sell more and make more money we’ve always found that a really good exercise to do, don’t just see compliances as a pain in the a** see it as a way of improving your business. So, mapping out the journey will pay dividends in general performance of your business, when it comes to monitoring you know that journey, that you’ve got a map now you have the experience mapped, how would you recommend firms monitor to make sure that the journey is going according to plan for all of the customers? Well I mean, that’s actually the second part of our exercise once you know what your outcome should be, each touch point you’ve then got to go, how do we measure it? like, again, when we did that exercise people are like ‘i’m already doing all these things’, like great can you prove it? and that was often the sticking point so you know it may be easy to track how many customers are using a certain product it’s very difficult to understand does a customer understand what you’re explaining you know are there any vulnerabilities you know what do your complaints mean and how should you feed that back to improve the start of the process that’s the difficult bit, if you haven’t got data, find someone who can help you with the data. Do you know of anyone Nick? yeah, me and you! But that’s not a loaded statement I always say I don’t look after our own IT support because you know that’s not our speciality we don’t do our own telecom that’s not our speciality we don’t do our own HR we have external HR, I wouldn’t want to do that, but you know if you can’t do it in your firm you should outsource, and that goes for compliance, call monitoring and maybe other things too. Fantastic, well thank you Nick for joining us, it’s been really great to have you and I’m sure everyone watching this will really find a lot of value and if they need to get hold of you how can they do that Nick? Find us online “The Compliance Guys”, LinkedIn, Facebook, website or me personally on LinkedIn, Nick McDonald, we never charge for a chat so if anyone wants to pick up the phone and chew the fat about compliance let’s do it and yeah good luck everyone. Fantastic Nick, thanks for joining us, cheers! Cheers, thanks!

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Identify and report all vulnerable customer cases

Optimise your approach to identifying, handling, and reporting on vulnerable customers.

It’s quick and easy to configure Voyc to raise alerts when a customer interaction shows signs of potential vulnerability. In fact, Voyc identifies 70 different types of customer vulnerability. Our customers use evidence provided by Voyc for MI reporting to the Board and the regulator.

Our Customers

Consistency in operating excellence
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