Time taking a break can provide an opportunity for reflection

Whilst there is a lot going on in the regulatory environment at present, we are all very busy and, therefore, some amongst us crave our downtime. Whilst we all say that when we go on holiday we look forward to just getting away from it all, it’s often a time for quiet reflection and many of us return with a clearer vision and a reinvigorated approach to the way we do business. With that in mind, I thought I would offer you an article this month that, whilst its focus is meeting the requirements the regulator expects from your firm, in honesty, it is good, solid best practice in business as well. 

In my many years as a compliance consultant, I have found that many issues faced by firms often come out of a lack of adequate communication, whether that be internal or external. Therefore, from the outset, I would like to remind you to clearly engage with your clients throughout the entire sales and funding process, from initial enquiry all the way through to completion and then beyond, and this will stand you in good stead. The FCA has a focus on ensuring those it regulates take steps not to ‘harm’ their clients  - and by this they mean that a client should be aware of all of the implications they may be signing up to, any things to consider and what is expected of them.

If you are up for some inward reflection:

• Consider your processes and whether they take into account the possibility that your arrangement could push your customer into financial difficulty and, therefore, do you fully assess customer vulnerability?
• What are your procedures in managing risk areas, such as incentives, outsourcing and customer complaints? Do you clearly communicate all that is needed to the client or do you just give them what you think they want to see?
• Do you make sure that your clients fully understand the product they subsequently agree to?
• If you have staff, do you have adequate oversight? Do you perform quality assurance checks to ensure that the agreements you put in place achieve their expected outcomes?

It all boils down to ensuring you are allowing your clients to make an informed choice through supporting information, your advice and whether you can demonstrate the reasons behind your solution selection and why it is right for them.

Your client should always be at the centre of your processes, so ask yourself – are you communicating with them in a clear, fair and never misleading manner?

It isn’t all about the business process however, what is your firm’s culture?   Are you engendering a positive culture across your firm?  Are your staff fully up-to-date with requirements and the standards you want to be in place for your clients.

Treating customers fairly is intrinsically linked into your approach and communication, do you demonstrate your approach to this area of focus throughout your firm.  Do you keep up-to-date with the variety of lending options in the market and do the lenders that you’ve developed relationships with over the years really offer the best solution for your clients’ circumstances?  Have you taken the time to explore the many new entrants to the market?  This is a fast moving industry and lenders are providing some new approaches to the more traditional lending solutions that could maybe meet some of your less traditional client needs. 

Ongoing relationships with your clients can produce a very lucrative relationships. Do you stay in touch and look for new solutions when the opportunity arises?  Do you assess how your last arrangement went for them?  Is there anything to be learned from each situation that you are missing by not following up? Making sure your solutions perform as expected is just sound business sense and every situation offers a learning opportunity.

Why not take the approach of putting yourself in your client’s chair and then ask yourself “Does my business achieve the right outcome?” and you will soon see that by doing so, it can work to your advantage as well.

Food for thought perhaps for the beach, the pool or just those quiet moments when your mind gets chance to wander - a little?  Happy holidays.