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Complaints Procedure

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Making a complaint

We work hard to ensure our Members act within the rules set by the industry regulators.

Please click on the following link and read our Code of Practice. If you think a Member has broken the rules of this Code you can make a complaint by downloading our Complaints Form.

Before making a complaint we would encourage you to carry out the following activities:

 

  • Go to the Members Directory and check whether the company you wish to complain about is a Member of the CSA. If you are still unsure, feel free to contact us. If the company is a Member of the CSA then we are able to help you with your complaint.
  • On first instance, we recommend you contact the Member company to discuss any issues you have and enquire about their complaints process. If you are still dissatisfied with the outcome then you can review our Complaints Procedure.
  • If you believe that the Member has acted in breach of our Code of Practice and the complaint meets the necessary criteria, please complete, sign and return the Complaint Form to our registered address.

CSA Complaints Procedure

 How we deal with your complaint.

All complaints must be submitted in writing, with a signed complaint form. We require the form to be signed so that we, and our Member, have the requisite authorisation to share information.

The following is the sequence of events after the CSA receive a complaint form;

  • CSA receive a signed complaint form
  • CSA register the complaint and send a copy to the relevant Member company
  • The Member is given four weeks to respond directly to the complainant
  • CSA get a copy of the response from the Member company
  • CSA considers both positions and determines whether the Code of Practice has been breached
  • Appropriate action is taken (if required) to remedy the situation
  • If further information is required the CSA contact the relevant party (the complainant or the Member company).
  • After a full review, the CSA provides a formal response to the complainant

 

If you remain unhappy with the outcome of the complaint, you may have justification to escalate the matter to our our head of compliance, Claire Aynsley, claire.aynsley@csa-uk.com.

 

Please note: The CSA can only intervene when;

  • a Member company is in breach of the Code.
  • the company is a Member of the CSA (we cannot act when the complaint is about the client of a Member company, a bank or building society for example).
  • the information supplied by a Member company appears from the facts to be incorrect.

Methods of Contact

 

Address

Credit Services Association

Complaints Department

2 Esh Plaza

Sir Bobby Robson Way

Newcastle-upon-Tyne

NE13 9BA

 

Why the CSA need a signed copy of your complaint

 

Top

08-12-2015

Blog: Opening new doors: The future of customer service-led doorstep debt collection

 

John Ricketts is vice president of the Credit Services Association and has been a member of the Institute of Credit Management since 1987. He is a senior debt collection executive with over 20 years CEO and Sales Director Board Level experience.

 

Doorstep debt collection has long divided opinion. Clients have often struggled with the concept of collecting money on the doorstep, despite its proven success as one part of a wider collections strategy. Public perception of bailiffs and the new challenges of compliance, have combined to make it too ‘high risk’ for many creditors, despite the fact that it has been proven to be an effective collection strategy with positive customer outcomes.

What is the role of a doorstep collector?

Contrary to the caricatured stereotypical image of somone bursting into people’s homes to remove TVs and other possessions, the main skill-set of a Doorstep Field Force, and the individual Field Agents/Authorised Representatives (‘agents’), is their ability to create a dialogue with a customer where no such dialogue previously exists. So is there a new, more contemporary vision for doorstep in a modern collections environment?

What if, for example, a new role for the agents could be found – in effect ‘re-connecting’ with customers regarding outstanding residential and business debts? Extending this idea further, could that same Field Force not adapt their skills to assist in other areas of client and customer service? If representing utility companies, for example, agents can logically assist with residential and business disconnections, safety inspections, and revenue protection – specifically the timely identification of unpaid gas or electricity services. They may also be able to assist in a broader ‘customer services’ role, providing support with meter readings, or simply checking if a premises is occupied or vacant. For the banks and other financial institutions, ‘re-connecting’ at an early stage with customers who have gone into arrears is a potential market opportunity, as is the ability to take a ‘statement of means’ for those looking to secure a new mortgage or loan.

Agents can also play a role in pre-repossession visits and providing support in terms of taking on new accounts or solving disputes with existing customers. And for the insurance industry, locos reporting, taking witness statements and general support with accident investigation are just some of the added-value services a Field Force can viably undertake. The scope of operations is considerable; evolve into these markets and the roles will evolve accordingly.

How has the new regulatory regime changed field collections?

Since the Financial Conduct Authority (FCA) took over as regulator, collections agencies have been nothing if not inventive. Whereas the emergence of a new regulatory regime may have served to put certain firms (and collectors) out of business, some have shown a more entrepreneurial spirit.

Fieldcall, for example, is one such firm that has risen to the challenge as group managing director Andy Fowler explains: “The field visit market has consolidated into a handful of credible, regulated, professionally managed and modern businesses that are no longer rewarded for the money they collect (in fact most no longer collect money) but for the information they supply,” he says. “As a result of this our businesses no longer specialise purely in financial services but have diversified and developed into a provider of services to the insurance industry, insolvency practitioners and landlords.” Key to enabling Fieldcall to rise to this challenge has been its use of technology: “All our agents utilise an iPad that has full end-user security with real time updates available to clients,” he continues. “It would have been inconceivable five years ago that major insurance companies would use the same company to visit in respect of a leaking shower claim who also visit individuals who are in arrears with their personal loan or mortgage but that is exactly what is happening. This is because the visit is undertaken in a professional and focussed manner with an emphasis on gathering information and able to provide that information in a way that enables the correct outcome to be delivered for the customer and is also able to do all of this using secure state of the art technology, without paper.”

Does doorstep collection still pose a reputational risk?

Andy argues that there is no longer any reputational risk associated with a field visit, in fact quite the opposite: “Over 98% of the people who we meet respond in a positive way to the experience,” he says. “And astonishingly, in the case of borrowers who are in payment difficulties, the earlier in the process the visit occurs the better the experience for the consumer as uncertainty is minimised.”

EOS Solutions UK is another firm that saw the arrival of a new regulator as an opportunity rather than a threat: “A core part of our preparations for FCA authorisation was the decision that we had to make regarding our field services offering,” explains Stuart Knock, managing director of EOS. “Our existing field service clients were exclusively utility businesses and so we did not need authorisation to maintain our field income. Our decision to seek FCA authorisation to act as a principal might therefore seem a little adventurous but this was linked to the Dator app that was then still in development which we saw as being a revolutionary concept and something unique to EOS. We knew the app would allow us to reskill our agents and improve their productivity by significant multiples, in turn improving our competitiveness. This we thought would open up new markets for our services, including the regulated sectors.”

For Stuart, reskilling field collectors and agents at a time when the focus on compliance was rising exponentially seemed an obvious step to take: “We had already decided that limiting interaction with the customer at the door would reduce risk and enhance audit control,” he says. “We made our intentions to the FCA clear from the outset, both in our business plan submission and the detailed follow-up questions that followed.” The field agent collects a new contact number from the customer, relays that in real time to a dialler and then moves on to the next visit: “The call opening with the customer contains an audit on the quality of the field agent’s interaction and we then conduct a full TCF conversation with the customer - all on a recorded call.”

How are we professionalising field collection with technology and innovation?

Stuart continues: “We undertake affordability assessments, recommend any assistance and agree repayment plans with the customer in the safety of their own home without the possibility of them being overheard by neighbours.” EOS Solutions calls this service On Demand Customer Contact: “The request to launch a call can be routed to our client’s in-house contact centre if desired so that they can directly re-establish a relationship with their customer,” Stuart explains.

Technology and innovation is similarly important to the team at FieldCall. Having committed to the FCA authorisation process, Andy put a dedicated resource in place to ensure his firm met all of the necessary regulatory requirements. It appears to be paying off: “This year my businesses will visit over 150,000 people; contrast that to three years ago when the number would have been closer to 30,000 and you can see how far the sector has come.”

Perhaps the ‘old style’ doorstep collections model is dead but a new ‘vision’ is ensuring that relevant skills are very much kept alive – for the benefit of both clients and customers.