A Guide to Handling Complaints · A Guide to Handling Complaints – v4.1 26/09/2019 [PUBLIC] ......

A Guide to Handling Complaints – v4.1 26/09/2019 [PUBLIC]

Complaint Handling

At The Right Mortgage and Protection Network, we are committed to satisfying our customers'

needs, however, due to the complex nature of Mortgage and Protection products it would be

naïve to expect that all transactions proceed without hiccup 100% of the time. That said,

complaints are generally few and far between. The complaints’ process is necessary, however,

to deal with client concerns should they arise. Although complaints are rare, we do our utmost

to put things right.

The aim of this guidance is to:

Make clear the regulatory guidance for the handling of complaints as set out in the

Financial Conduct Authority handbook;

Set out the network’s processes for dealing with complaints;

Clarify the roles and responsibilities of Appointed Representatives (ARs), staff and the

complaint handling function in resolving complaints.

This procedure sets out the standards and the requirements that both the Network and by

extension Advisers must follow to ensure that all complaints are handled fairly, effectively and

promptly. It should also help to resolve any complaint at the earliest possible opportunity,

minimising the number of complaints referred to the Financial Ombudsman Service and

helping to improve general business standards, ensuring better outcomes for consumers.

As a network, the ultimate responsibility for all complaint related issues lies with us, therefore,

in line with the Network Professional Indemnity (PI) insurance policy, we require that all

advisers and staff, follow the procedures outlined in this document. It is imperative that all

become familiar with their obligations concerning complaints handling.

It is important that all advisers and staff are vigilant regarding any complaint or, indeed

potential complaint. Areas requiring particular attention include:

A breach of FCA Rules or guidance, or;

A failure to comply with any obligation arising under or by virtue of the Financial

Services and Markets Act 2000, or;

Negligence, a breach of a term of any customer agreement or any enactment or other

rule of law which may be applicable to the business of the firm, or;

Misrepresentation, bad faith or other malpractice.

A Guide to Handling Complaints


Should you receive a complaint or

suspect that a situation may give rise to a complaint, you must notify the Compliance Director

immediately, who will deal with the complaint in accordance with this guide.

All staff and advisers should be familiar with the Guide to Handling Complaints.

Firms must not charge a fee for providing written details of its internal complaints procedures

and must ensure that a complaint may be made free of charge.

Responsibility to the Customer

Customer complaints whilst unfortunate, do happen; and how a complaint is handled will be a

key factor in the customer’s decision whether to use a service again or whether or not to make

a recommendation to friends and family.

Insight gained from customers during the handling of a complaint can be used to improve

service standards and address training needs.

As part of the The Right Mortgage and Protection Network, Advisers are subject to the general

regulatory requirement that customers experience good outcomes in their dealings with the

network.

A good customer outcome will be the result of a ‘fair and proportionate’ investigation into the

customers concerns, considering all available evidence and coming to a reasonable conclusion

that avoids consumer detriment.

Complaint Definition

The Financial Conduct Authority Definition of a complaint is:

…any oral or written expression of dissatisfaction, whether justified or not, from, or on

behalf of, a person about the provision of, or failure to provide, a financial service, claims

management service or a redress determination, which:

alleges that the complainant has suffered (or may suffer) financial loss, material

distress or material inconvenience; and;

relates to an activity of that respondent, or of any other respondent with whom

that respondent has some connection in marketing or providing financial services

or products or claims management services, which comes under the jurisdiction of

the Financial Ombudsman Service.

https://www.handbook.fca.org.uk/handbook/glossary/G869.html

https://www.handbook.fca.org.uk/handbook/glossary/G3593c.html









But what really constitutes a ‘complaint’?

Sometimes, in the course of dealings with a customer, it may be difficult to identify when an

Adviser should invoke its complaints procedure. Customer conversations or correspondence

that feature statements such as "I’m making a complaint” or “l want to complain” are relatively

straightforward to identify; but phrases such as "you should have handled that better”, “it's

taken you ages to deal with that request and I’m not happy”, “all this waiting around is costing

me money”, or similar words and phrases would all amount to "expressions of dissatisfaction”

to which complaint handling procedures should be applied.

It is understandable that sometimes an adviser may choose to focus on “getting the job done”

for a customer, rather than focussing on the precise words that a customer uses; however,

listening to customers and probing sufficiently so as to discern whether or not they are

‘dissatisfied’ to the extent of wishing to pursue a complaint, is an important skill.

Please speak with your Compliance Manager should you be unsure on what constitutes a

complaint, they will be happy to help.

Please remember, a complaint can be made verbally or in writing and an adviser should not

insist on the customer confirming their complaint in writing if it is made verbally.

Eligible Complainants

It must also be noted that the Financial Ombudsman Service will only deal with a complaint if

it is brought by or on behalf of an eligible complainant. Eligible complainants are defined as

follows:

A consumer (A service user);

A ‘micro enterprise’ (defined as: employees fewer than ten persons and has a turn over

or annual balance sheet of less than €2 million);

A charity, which has an annual income of less than £6.5 million at the time of the

complaint;

A trustee of a trust which has a net asset value of less than £5 million at the time of

complaint;

A Consumer Buy to Let Customer (CBTL credit agreement or a person acting in relation

to buy to let business that is outside of their business or trade);

A small business (not a micro enterprise, annual turnover of less than £6.5 million,

employs fewer than 50 people or has a balance sheet of less than £5 million);

A guarantor.

Further guidance regarding eligible complainants is available in DISP 2.7 of the FCA handbook.

Occasionally, Advisers might receive complaints from larger businesses (e.g. those running

larger, complex buy to let portfolios or operating group PMI schemes) or other persons or

organisations who do not meet the criteria of an ‘eligible complainant’. Complaints from these

sources will be treated as unregulated complaints.


Additionally, an adviser may receive a complaint where it is unclear whether the Adviser and/or

the Network should be responsible for resolving, for example, complaints that relate to:

Unregulated products;

The activities of a third party, such as a product provider or lender, or another adviser;

The period of time before sale of the product was regulated by the FCA (or its

predecessor, the FSA)

Complaints of the nature mentioned above should be forwarded immediately to the

Compliance Director who will assess and categorise the complaint appropriately.

Regulated, Simplified and Unregulated Complaints

Advisers are likely to receive complaints that will fall into three broad categories; Regulated,

Simplified and Unregulated. Each category of complaint is subject to a different process within

the network and are treated differently by the complaint handling function.

The common characteristics of complaints that may fall into each category are:

Relate to advice received/performance of product

recommended (e.g. mortgage affordability or policy coverage

declined);

More complex, DISP requires resolution within 8 weeks;

Financial compensation sought typically moderate to high.

Relate to service provided/administration or processing

mistakes;

Should be capable of being resolved without in-depth

investigation, DlSP resolution within three days;

Goodwill gestures such as vouchers/flowers/an apology

appropriate to preserve relationship with customer;

Financial compensation sought - typically low.

Relate to products or services which are not subject to FCA

regulation and/or are outside the jurisdiction of the FOS;

Customers are not eligible to complain;

Captures complaints regarding ancillary services such as wills

and trusts, conveyancing referrals, surveys arranged;

Complaints that go straight to court proceedings rather than

following the ‘Regulated’ 8-week process.

REGULATED

SIMPLIFIED

UNREGULATED


Simplified Complaints

The Financial Conduct Authority allows for complaints that are able to be resolved by the close

of business on the third working day to be dealt with in a somewhat simplified manner.

Therefore, their rules regarding timescales and complaints forwarding do not apply; however,

the complaints resolution rules still apply.

Should a complaint be dealt with in line with this ‘three-day rule’ there is no obligation for the

acceptance of the resolution to be in writing; however, the network will respond to the client

providing a ‘summary resolution communication’ that will refer to the following:

Nature of the complaint;

That the complaint has now been resolved;

The client may be entitled to approach the Financial Ombudsman Service should they

subsequently be dissatisfied with the outcome;

Whether or not they are prepared to waive the resolution time limits;

The details of the website address for the Financial Ombudsman Service;

Refers to the ability to obtain further information from the website of the Financial

Ombudsman Service.

This communication must be clear and unambiguous; it should clearly set out the matters

involved and the responses to the complaint.

Regulated Complaints

As already mentioned, it is our goal to deal with all complaints as speedily as possible,

therefore if we are able to resolve the matter and are in a position to provide a final response

within five business days of receipt of the complaint we will write to the consumer to both

acknowledge the complaint and provide our final written response.

Where we anticipate the resolution of the complaint taking in excess of five business days, we

will first write to the consumer acknowledging their complaint (within five business days). We

will also use this opportunity to outline our complaints process and provide details regarding

any potential recourse via the Financial Ombudsman Service.

Should a complaint be received after 5pm on a business day, or on a non-business day, we

will treat it as having arrived on the business day immediately following the arrival of the

complaint.


Receiving Complaints

A Complaint may be received via any reasonable means, such as; by letter, telephone, email,

fax or in person.

All complaints should be investigated competently, diligently and impartially.

Details of the Complaint should be recorded on the Network’s complaint register.

Advisers are also expected to keep their own Complaint Register.

All complaints must be passed to the Compliance Director for investigation immediately

(details below):

If the complaint is made verbally, a record of the conversation must be compiled including the

following information:

Name, address and telephone number of complainant;

Name, address and telephone number of client (if different from complainant);

Date and time of complaint;

Nature of complaint;

Name of Adviser (if known);

Name & title of staff member receiving the complaint.

Only the Network should respond to complaints, whether or not they fall under the jurisdiction

of the Financial Conduct Authority. This does not prevent other persons undertaking research

or review into the complaint; however no other person may respond to the complainant unless

we have given that person our express permission to do so.

You should not initiate contact with the customer until the Compliance Director has informed

you, in writing, that it is permissible to do so.

Compliance Director

The Right Mortgage

St John’s Court

70 St John’s Close

Knowle

B93 0NH

[email protected]


Complaints Investigation Process

This guidance explains how advisers should deal with a complaint that is either Regulated,

Simplified or Unregulated.

It is important that a complaint is categorised correctly as soon as possible following receipt

to ensure that the customer is dealt with in a manner and within a time frame that is

proportionate to the nature of the complaint made. Correct categorisation at the outset will

also allow relevant experts to be consulted and should ensure that any professional indemnity

insurance cover that may subsequently be required is preserved in accordance with policy

terms.

The role of the Adviser and Complaint Handling Function in relation to each category of

complaint is:

Advisers are required to maintain logs of all complaints received,

including those passed onto the Complaints Handling Function.

Logging a complaint on receipt is important to generate a record of

when the complaint was received for DISP purposes.

The category of complaint ls important to be certain of its treatment

Unregulated complaints to establish If the network is responsible or

should forward the complaint to a third party, Regulated and

Unregulated complaints may also require notification to Pl insurers.

The extent of the investigation should be proportionate to the nature

of the complaint.

A review of the case would be undertaken and a confirmation that the

consumer was happy with the outcome is required.

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Receipt and

Logging

Categorisation

Investigation

Initial Decision


Adviser/AR opinion in relation to the likely findings on the complaint

should be sought

Professional Indemnity Insurance policy requirement to approve draft

response on complaints that are not Simplified complaints.

Simplified Complaints require the issue of a Summary Resolution

Communication (SRC).

Regulated and Unregulated Complaints require the issue of a Final

Response Letter (FRL).

Where a proposal to settle a complaint has been accepted by a

customer all outstanding actions should be followed through before the

complaint is closed.

Any referrals to the Financial Ombudsman Service arising from any

complaint will be held by the Complaint Handling Function

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Advisers CHF

Regulated

Simplified

Unregulated

Adviser/ AR

Feedback

PI Approval

SRC/FRL

Process

Settlement

FOS Process


ARs are required to maintain internal logs and to report all Simplified

complaints to the Network.

Upon receipt of the complaint the Compliance Director will appoint a complaints handler to

investigate the case and compile all relevant information for review. This person will carry out

a balanced and objective investigation, taking into account the complainant’s version of the

events that gave rise to the complaint, the response of the adviser and all supporting evidence.

A complaints file will be kept up to date at all times, containing all relevant information such

as records of telephone calls, copies of all correspondence sent and received in connection

with the complaint, e.g. product provider literature, written reports, letters, emails etc.

Once all of the information has been gathered the complaints handler will consider an

appropriate course of action and will make a recommendation to the Compliance Director and

subsequently the PI Insurer.

All staff involved with any investigation will be suitably competent.

Principles of Complaint Handling

The Complaint Handling Function and ARs will be expected to observe and apply the following

principles when dealing with complaints:

Treat customers fairly and deliver good customer outcomes;

Deal with all customers professionally and respectfully;

Ensure compliance with this guidance (which itself complies with the requirements of

DISP) in particular, the steps to be taken by an AR in dealing with a Complaint, set out

below;

Maintain AR complaint logs;

Implement improvements in policy, guidance or process as a result of Complaint

decisions to address root causes of Complaints.

Advisers CHF

Regulated

Simplified

Unregulated

Closure and

Reporting


Adviser Responsibilities:

Maintenance of a Complaints Log - Advisers are required to maintain an internal

complaints log. An example of an acceptable complaints log is available from the

Members’ website or from your Compliance Manager.

Dialogue with the Customer - Following receipt of a complaint, advisers are advised

against maintaining a dialogue with the customer in relation to the complaint. The

Complaint Handling Function will have acknowledged the complaint directly to the

customer and the customer will have been provided with details of who to contact

during the on-going investigation. Any intervention on the part of the adviser could

cause confusion to the customer, potentially compromise the investigation or even

invalidate the Pl Insurance.

In the event a customer does make contact directly with the AR against which the

complaint has been made, brief notes should be made of the contact with the customer

(a useful way is to send an email to yourself to then drop into the complaint file). The

Complaint Handling Function should also be made aware of the contact and provided

with copies of any notes.

Where a complaint is received during the course of a transaction with a consumer, e.g.

during the mortgage application and approval process, the adviser should establish

whether the customer wishes to proceed or to seek advice elsewhere. If the customer

does wish to proceed then the adviser must keep the Complaint Handling Function

informed of all material developments as these may impact on the approach adopted

to the complaint case.

Notification of a Complaint – It is the responsibility of the adviser to notify a

complaint (any expression of dissatisfaction) to the Compliance Director immediately,

using the term “Complaint” in the subject title. Failure to appropriately notify a

complaint could be considered a ‘breach’ and would be notifiable to the Regulator.


The Complaints Procedure

The following is an outline of the steps that the Complaint Handling Function will take to

resolve the complaint:

STEP 1 STEP 2 STEP 3 STEP 4 STEP 5

RECEIPT INVESTIGATION DECISION SETTLEMENT REPORTING

Enter details on

to the ZoHo

system used for

recording

complaints

Acknowledge

customer

Confirm

category and

responsibility

Prepare initial

response to

customer in line

with complaint

‘type’

Obtain all relevant

information and

accounts in

preparation for

investigation

Consider

relevant

paperwork,

emails, texts

and calls

Present details of

investigation to

Compliance

Director for

assessment and

decision

Upheld or Not

Upheld

Issue Final

Response Letter

/8 week

Letter with FOS

rights

Where offer to

settle is (formally)

accepted ensure

payments are

made in a timely

fashion

Update the

complaints log

Update AR

Report as

appropriate to

the FCA and any

third parties

The steps are explained in more detail below:

Step 1 - Receipt

Tasks Included: Acknowledgement, logging, categorisation and time limits

Ensuring that the complaint is logged, categorised and dealt with in accordance with

applicable time limits is an important step.

Compliance with the FCA handbook (DISP), and, by extension this guidance, requires that

regulated complaints are resolved at the earliest possible opportunity and, in any event,

resolved by the end of eight weeks after the receipt of the complaint. The Complaint Handling

Function also applies the eight-week period to the resolution of unregulated complaints.


Step 2 - Investigation

Tasks Included — Information gathering of all relevant communications

The Complaint Handling Function will request the AR to provide all the information that is

likely to be relevant to the assessment of the complaint. This may involve:

Emails;

Text Messages;

Call recordings (where available);

Notes of telephone calls;

Voicemails;

Any other documents or correspondence relevant to the advice process (Anti Money

Laundering compliance, disclosure, fact find, sourcing records, research, application

forms, offers, suitability/demands and needs letters etc);

Anything else that the Complaint Handling Function considers relevant.

It is important to remember that Complaints will relate in the main to issues with the suitability

of the advice provided to the customer. The Complaint Handling Function may refer to third

parties for any information that it considers appropriate e.g. packagers, master brokers, lenders

and/or providers.

Advisers are expected to co-operate with the Complaint Handling Function and to respond to

requests received within the timescales specified. Failure to do so could result in disciplinary

action being taken by the Network. Advisers are expected to disclose all relevant information,

even if it appears that the information may support the customer’s complaint.

During the course of the investigation the Complaint Handling Function will maintain regular

contact with the consumer, ensuring they are kept informed of progress, as required by the

Financial Conduct Authority.

Step 3 – Decision

Tasks Included - Resolving the Complaint, upholding or not upholding and remedies and

compensation

A regulated complaint should be resolved and evidenced by the issue of a Final Response

Letter, by the end of eight weeks after the receipt of the complaint. If at the 8-week deadline

the Complaint has not been resolved then the Complaint Handling Function will inform the

customer of their right to approach the Financial Ombudsman Service.

If it is more likely than not that the adviser fell short in its advice standards, or that an

administration error was probably due to the fault of the adviser, then the complaint is likely

to be upheld and a remedy offered. If the Complaint Handling Function is confident that the

adviser was not at fault then the complaint decision should be that it is not upheld. Not

upholding a complaint does not prevent the Complaint Handling Function offering a goodwill

gesture to the customer if it considers it appropriate to do so.


The Complaint Handling Function will seek the opinion of the adviser concerned, where this is

possible, prior to the issue of a Final Response Letter. Where there are points of disagreement

between an adviser and the Complaint Handling Function with regard to either the outcome

of the complaint or the redress offered, these will be subject to line management review within

the Complaint Handling Function. Representations of the adviser and the Complaint Handling

Function will be taken into account and the decision that senior management of the network

take in relation to the complaint will be final and binding.

There are a range of remedies that the Complaint Handling Function can choose from to assist

in the resolution of a Complaint. These are:

Verbal and written apologies;

Implementing a course of action to provide a practical solution to the problem or so

that the situation does not arise again;

Small gifts (e.g. flowers/chocolates/vouchers);

Refunds of fees or premiums paid (whether in whole or part);

Payments to compensate customers for distress and inconvenience;

Other compensation.

The aggregate monetary value for the remedies set out above, or any combination of

remedies, is determined by the Complaint Handling Function. The redress assessment for a

Complaint will take into the account actual financial losses suffered by the customer, the

impact on the customer of the issue that gave rise to the complaint and the distress and

inconvenience suffered. Each case is assessed on its own merit, taking into account previous

decisions made by the Complaint Handling Function or received from the Financial

Ombudsman Service.

When the Complaint Handling Function is confident that the Complaint has been resolved

(whether upheld or not upheld), the customer will be issued with a Final Response Letter which

will also set out the right of the customer to approach the Financial 0mbudsman Service.

Step 4 - Settlement

Tasks included - Implementing actions agreed with the Customer

The Complaint Handling Function will oversee the completion of the steps that have been

agreed with the customer to resolve the Complaint. This may mean physically sending a letter

of apology, flowers or processing a refund of fees or premiums or paying compensation.

Step 5 — Reporting and Post Complaint Review

Tasks included - Closing the Complaint and Addressing Root Causes

When the Complaint Handling Function is confident that the Final Response Letter has been

issued to the customer and all actions agreed with the customer have been completed, the

complaint can be marked as closed on the network (and adviser’s) complaint log.


Where the Complaint Handling Function considers that a Complaint case has given rise to

learning and development points for the network, a firm or an adviser, these will be

communicated appropriately.

Complaints Referred to the Financial Ombudsman

The Final Response Letter contains details of the customer’s right to approach the Financial

Ombudsman Service if they remain dissatisfied with the Complaint decision.

In the event that a complaint is referred to the Financial Ombudsman Service a formal response

will be prepared as follows:

A copy of the client file and any other supporting documents;

A summary of the complaint (where necessary, although often the Financial

Ombudsman Service will provide this directly);

An explanation of the decision made and why;

A copy of all letters to the client, including the final response letter;

Any additional comments that we feel the FOS should be aware of.

The complaint will then be investigated by a case adjudicator before the Financial Ombudsman

makes a final ruling on the case. Once this final decision has been made it cannot be

challenged. Should the complainant disagree with the final decision of the Financial

Ombudsman their only option is to take legal action.

All correspondence and communication with the Financial Ombudsman Service will be made

through the Complaint Handling Function, or subject matter experts dealing on its behalf.

Advisers may be consulted as part of progressing a case with the Financial Ombudsman

Service but will not deal with the Financial Ombudsman Service directly.

The Financial Ombudsman Service charges a case fee of £550 per case and this cost may be

charged back to the AR against which the complaint has been made – this is at the discretion

of the board of directors.

The Complaint Handling Function will challenge the Financial Ombudsman Service where it

believes that they have levied a case fee unfairly.

Financial Ombudsman Service Contact Details

In Writing: Financial Ombudsman Service

Exchange Tower

Harbour Exchange

London

E14 9SR

Email: [email protected]

Website: www.financial-ombudsman.org.uk/contact-us/complain-online

Telephone: 0800 023 4567

mailto:[email protected]

https://www.financial-ombudsman.org.uk/contact-us/complain-online


Professional Indemnity Insurance (PI Insurance)

One of the benefits of being a member of The Right Mortgage and Protection Network is that

we provide you with a Professional Indemnity Insurance Policy. This policy requires that you

notify all complaints to the Compliance Director and where these cannot be quickly (3 working

days) dealt with they should be communicated to the PI Insurer.

We will explain to the PI Insurer:

The potential claim / compensation amount and whether or not it is within the policy

excess;

Views on liability;

Whether or not you/we consider the complaint to be spurious or without foundation.

You must not:

Admit liability;

Settle or make or promise any payment;

Disclose you are covered by Professional Indemnity Insurance;

Disclose you have made or are intending to make a notification under our Professional

Indemnity Insurance;

Take any action which might prejudice our insurer’s position or their ability to

investigate a circumstance or claim.

Due to the nature of the PI policy we, as the Network, will deal directly (and on your behalf)

with the insurer.

When reporting a complaint, the PI Insurer requires that all circumstances are disclosed.

It is also a requirement of the PI Insurer that the Network Sales Process has been adhered to,

should you have circumnavigated this process you may invalidate your right to claim against

the Policy.

Failure to observe any of the prescribed complaints handling procedures in a timely

manner may invalidate the terms of our network PI Insurance policy and may involve

additional compliance investigation costs.

We may also suspend your permission to act as our AR in the event of non-cooperation

or any attempt by you or anyone connected to your firm to impede the process of

investigation.


Timescales

As already mentioned, we will endeavor to address all complaints as quickly as possible.

Within five working days of the complaint being made to the firm, the Complaints Handler will

send a written Acknowledgement Letter confirming:

Receipt of the complaint;

The name or job title of the individual handling the complaint;

Details of the Internal Complaint Handling Procedures;

An Authority Letter to be completed and returned by the consumer (This is to give the

Complaints Handler the authority to contact any third parties as may be necessary).

Four Week Response

It is possible that a complaint is able to be resolved within four weeks, however, where this is

not possible, the consumer will be provided with a ‘four-week’ response letter, outlining any

progress and advising when the consumer can expect a response.

Eight Week Response

Eight weeks (or less, where possible) from receipt of a complaint a final response letter will be

issued which explains the investigations undertaken and details the findings. If it is not possible

to respond within eight weeks (perhaps due to delays in obtaining information or delays

relating to the investigation which are beyond the control of the Complaints Handling

Function), we will provide the consumer with an explanation as to why we have not resolved

the complaint. This response will include an explanation as to why there has been a delay and

when a final response is anticipated to be ready. At this stage the consumer is entitled to take

their complaint to the Financial Ombudsman Service. A copy of the Financial Ombudsman

Leaflet entitled “Want to take your complaint further?” will be supplied at eight weeks.

Final Response

The final response letter will include the following:

An explanation that you may refer your complaint to the Financial Ombudsman

Service if you are not entirely satisfied with the final response that you receive

from us. This letter will also explain that you have six months to do this;

We will also enclose a copy of the leaflet ‘Your Complaint and the Ombudsman’.

Training

The induction course outlines the complaints process and what is expected of an adviser when

a client makes a complaint. Additionally, this is recapped for all advisers as part of their

Guidance Visit (within one month of joining the network) and each Appointed Representative

(firm) is assessed as part of the audit visit.


It is the responsibility of the firm principal to ensure that all persons within their firms are

familiar with the complaints handling process.

Any new joiners to your firm must be made aware of these procedures immediately upon

joining.

Skill, Care & Diligence

At The Right Mortgage we pride ourselves on the quality of our staff and our advisers, we

therefore genuinely hope that consumers do not have cause for complaint, however, please be

reassured that should a consumer need to complain, their complaint will be handled by

someone who has many years financial services experience and has the necessary training and

skill to do so fairly, quickly and impartially.

All complaints are shared with the Board of Directors so that all outcomes and learning points

are considered and subsequent training can be undertaken.

Complaints Relating to Previous Networks or Employment

You will be responsible for responding to the complaint.

At your own expense, you will need to appoint an Investigating Officer who is suitably

competent to investigate the complaint and should not be directly involved in the matter. The

Investigating Officer should handle the complaint in accordance with the FCA rules detailed in

the handbook.

The Right Mortgage can take no responsibility for any complaints arising from advice given or

business written prior to joining the network.

It is your responsibility to ensure that you have sufficient insurance cover relating to complaints

that pre-date you joining The Right Mortgage and Protection Network.

Record Keeping

As previously mentioned, you must maintain a complaints register and it should be kept up to

date at all times. It is best practice to keep the register up to date even when you have not

received any complaints. A simple ‘nil return’ on a monthly basis will suffice.

Further Assistance

Any queries with regard to the application or the interpretation of this guidance should be

referred in the first instance to your Compliance Manager.


Conclusion

This guide has been written in accord with the procedures set out for complaints handling as

written by the Financial Conduct Authority within its DISP (Dispute Resolution) Handbook.

Consideration has also been given to guidance from the Financial Ombudsman Service.

This guide will be reviewed annually to ensure that it continues to be appropriate.

A Guide to Handling Complaints · A Guide to Handling Complaints – v4.1 26/09/2019 [PUBLIC] ......

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Transcript of A Guide to Handling Complaints · A Guide to Handling Complaints – v4.1 26/09/2019 [PUBLIC] ......