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What You Need to Know About Customer Complaints Management in Financial Services

By Karen Oakland, VP of Financial Services Marketing at Smart Communications 

Complaints management can be a costly affair, especially for regulated industries like financial services and insurance. Support staff and call centers are expensive, which is why improving digital self-service capabilities is an important priority for many financial institutions. Meanwhile customer expectations for fast response time and personalized attention are higher than ever. 

Apart from managing customer service costs, businesses now need to factor in the cost of reputational damage when customer complaints are aired in the digital arena. No company wants to be “flamed” online. Yet the trend has been for customers to voice complaints on social media rather than through traditional channels like contact centers or complaint letters, particularly among younger generations.

In financial services, customer complaints management is drawing the attention of federal and regional regulators. In Australia, regulators are taking a stronger approach to consumer protections that sets a precedent for rules makers in other countries, such as the Consumer Financial Protection Bureau (CFPB) in the U.S., and the Financial Conduct Authority (FCA) in the U.K. 

Here’s what you need to know, and some tips for how your business can more effectively manage complaints and credit disputes (even if you’re not operating Down Under). 

What are the Key Provisions of Australia's RG271 for Complaints Management? 

In Australia, financial services institutions (FSIs) are regulated by the Australia Securities and Investments Commission (ASIC), which acts in partnership with Australian Prudential Regulation Authority (APRA). In October 2021 ASIC issued Regulation Guide 271 (RG271) for Internal Dispute Resolution, or IDR.  

Some key provisions of RG271 include: 

  • Expanding the definition of "complaints" to include dissatisfaction with a company, its staff, products or services  

  • Expecting financial institutions to proactively address complaints, even those expressed on social media and not submitted directly or in writing 

  • Ensuring ease of complaint filing for customers and providing clear communication about the complaint process 

  • Requiring financial institutions to acknowledge a complaint within 24 hours 

  • Mandating a written response with the outcome of the IDR process to be delivered within 30 days (reduced from the previous 45-day timeframe) 

  • Requiring FSIs to record all complaints and regularly report to the company's board and senior management 

  • Introducing a new IDR data reporting framework, necessitating the submission of reports to ASIC every six months on complaints handling starting in 2023 

Different timeframes apply for resolving certain types of complaints, including those related to superannuation (or retirement fund) death benefit distributions; credit-related complaints involving default notices; and those involving hardship notices or requests to postpone enforcement proceedings. 

While these requirements may seem straightforward with the advancements in digital technology, regulators believe that many banks and other FSIs struggle due to inadequate capacity and resources to investigate and resolve customer complaints promptly. 

In fact, the ASIC found late last year that 20 percent of all superannuation funds were still not meeting the regulatory requirements for communicating with customers as part of a dispute resolution process. And it said that 80 percent of the funds were poorly managing systemic issues around complaints management. Most failed to ensure all complainants were kept informed within the required time frame. If your business wants to improve in this area, here are three areas to consider. 

 
1 in 5 super funds fail to adhere to ASIC’s dispute resolution guidelines – InvestorDaily 

How to Ensure Compliance with Complaints Management Regulations 

The Smart Communications Conversation Cloud™ (the combination of our cloud-based customer communications management solution, SmartCOMM™, and forms automation solution, SmartIQ™) platform offers capabilities that can help your organization achieve RG271 compliance for IDR in Australia, or simply enhance the effectiveness of your customer support operations, in the following ways:  

  1. Rethink your use of traditional forms to capture data on complaints. For many customers, forms are frustrating and mind numbing. Moreover, they often require manual work for internal employees to process and retype data into other systems. Our SmartIQ forms automation software supports digital and mobile interactions, while making it faster and easier for FSIs to process the information with connection to employee task dashboards and workflows. This type of guided interview can elevate your customer self-service and can be used in internal contact centers to improve efficiency. And with a low-code architecture, you minimize the burden on IT. (Take a closer look within our Ultimate Guide to Digital Forms Software.) 

  2. Utilize customer communications management (CCM) software to centralize your templates for complaints communications across output channels. SmartCOMM, our cloud customer communications management (CCM) solution, enables FSIs to be confident that every message and document is compliant, from automatic acknowledgements to IDR responses to regulatory reporting. Cloud-native, SmartCOMM provides prebuilt integrations to CRM, intelligent automation and ECM archives, giving you even more cost efficiency and flexibility to design the best customer journey. If you use a process automation solution like Pega or Appian, for example, you can use those solutions to trigger these dynamic communications to be sent via the customer’s channel of choice. With our Pega connector, customer service representatives have the ability to create ad-hoc letters and correspondence from within that user interface. 

  3. Improve insights into complaints using content intelligence. With our built-in content intelligence capabilities, you can understand where customers are missing questions in a complaint interview, or where customer communications can be improved across the lifecycle. With our Content Intelligence module, you can evaluate the readability, sentiment and tone of communications to make sure they are both empathetic and effective. 

At its core, resolving complaints and disputes requires a two-way conversation between the customer and your support team. Resolving them quickly means re-imagining that conversation in a digital-first world, improving the ability to self-serve. By leveraging the power of composable, cloud-based software platforms, you can connect all your touch points and remove points of friction. 

Case Study: Digitizing Credit Card Dispute Resolution for Improved Complaints Management 

Here’s a real-life example that illustrates this new way of thinking. We’re working with one of our largest banking clients in Australia to re-imagine the customer experience and digitize the process of resolving complaints such as credit card disputes. Like many services requests, the resolution process requires the customer to submit a form to start the process. 

Historically, that form was only available as a blank PDF the customer was required to download and complete on paper. Why was this a problem? 

  • It wasn’t an easy experience – and not mobile friendly 

  • The burden was on the customer to complete it correctly 

  • It required an employee to rekey data into another system – with the risk of NIGO errors 

  • That data needed to be input into another system before any process automation could begin 

With SmartIQ, the bank is now able to provide branded, device-responsive digital interviews from within its secure customer portal. Integrated with the bank’s CRM system, these guided “forms” are prefilled, making it easier for customers to complete and reducing errors thanks to real-time data validation. 

In addition, the data automatically generates acknowledgements and other customer communications as required by regulators – all integrated seamlessly with the bank’s e-signature and document archiving solutions. The incoming data further triggers automated processing via Appian, ultimately speeding up compliant resolution time and improving customer experience. 

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Enable customers to easily upload supporting documents and switch between mobile or desktop. 

Resolving Customer Complaints Faster Has Long-Term Impact 

Beyond the regulatory “bite” of potential fines and penalties, improving the way you manage complaints and disputes can deliver results in terms of greater efficiency and customer loyalty scores. Many organizations today are adopting the use of “Customer Effort Scores” as a key measure of client satisfaction, in addition to traditional churn metrics, according to analysts like IDC. 

Our benchmark research reveals that 81% of global consumers consider the communications they receive as important to their overall experience with a company. The increasing number of communication channels, coupled with customers’ ever-changing expectations, is putting more pressure than ever on financial institutions to keep pace across every interaction, not only in complaints management. 

At the same time, you’re continuing to face cost pressures and need to squeeze efficiencies out of every process to stay competitive in a volatile economy. Servicing is still primarily a cost center, not a profit center. That means it’s more important than ever to automate and streamline your complaints management processes while deploying your staff where they provide the most value. 

If you’d like to talk about ways to take your complaints and disputes management process to the next level, reach out and talk with us.  

FCA Compliance: Consumer Duty and the Impact on Financial Services Communications

By: Karen Oakland, VP of Financial Services Marketing at Smart Communications 

One of the key industry regulators in the U.K., the Financial Conduct Authority (FCA) has introduced a new directive aimed at protecting banking and financial advisory consumers, which has significant compliance implications for more than 58,000 businesses in the region. Following on the heels of its Vulnerable Customer regulation, the FCA’s new Consumer Duty regulation addresses not only the ways in which financial institutions communicate with their customers, but also how easy they make it for customers to engage in return. 

Consumer Duty was rolled out quite quickly – and with the FCA’s final guidance spanning 121 pages, it’s a lot to take in. Many organizations are wondering exactly how it will affect them and what they need to do to ensure FCA compliance. Let’s look at what this new regulation means and how you can leverage it as an opportunity to improve customer communications and service, rather than an obstacle to work around. 

What is Consumer Duty and When Do FCA Rules Apply?  

Consumer Duty is a set of rules for financial services firms that enforces greater consumer protections. Banks must align to its overarching principles: that communications sent to consumers should be easy to understand, products and services should meet their needs and offer fair value, and consumers should be able to get the support they need, when they need it.  

The FCA developed these Consumer Duty compliance guidelines to enforce these principles as part of a paradigm shift it hopes to influence in both the culture and conduct of financial institutions. Financial services and insurance firms operating in the U.K. were required to have an implementation plan in place for FCA compliance with Consumer Duty by October 2022, and need to have rules in place for open products and services by July 2023 and for closed products and services by July 2024. (Note that organizations in the U.S. market are seeing similar regulations from the Consumer Financial Protection Bureau / CFPB.) 

FCA Compliance Implications for Financial Services 

Several of the Consumer Duty’s key requirements call for firms to improve the customer experience. If your business operates in the U.K., while it’s easy to view these as more regulatory hoops to jump through, they present an opportunity for your organization to assess current communications across the entire customer journey and identify where and how you can do better. Here are three examples. 

1) Fast-Tracking Customer Support 

One Consumer Duty requirement dictates that firms must “provide helpful and accessible customer support.” That means making it faster and easier for consumers to get the answers they need, and not making them wait so long for an answer that they give up.  

To comply with this mandate, firms will need to centralize processes for collecting client information, so that it can be used to trigger automated responses and so that it’s available to support contact center agents or financial advisors in real time. In addition, firms will need to offer more robust self-serve options on digital and mobile channels, such as smarter chatbots, to save customers from having to call a contact center and wait on hold. The goal should be to make it possible for customers to get whatever help they need in the most convenient way possible – on the channel of choice. 

2) Revising Communications for Clarity and Readability 

Consumer Duty also requires firms to provide timely and clear information so consumers can understand the products and services they buy and make sound financial decisions. Rather than burying key details in lengthy terms and conditions that few people actually read, firms must work to make communications clear and readable, and be able to prove that they’ve taken steps to optimize their communications. 

Additionally, financial services firms must provide products and services that are right for clients – that is, personalized to their needs. This means organizations must provide clear, transparent communications that guide clients to the right decision for their unique circumstances. This also means maintaining a full audit trail showing when and how communications are updated for FCA reporting. 

3) Shining the Light on Communication Pain Points 

Consumer Duty is all about making things easy for the customer by asking financial institutions to optimize their communications – to make sure customers understand things like the cost of the financial products they own and how to use their benefits. In addition to reviewing and optimizing customer communications, firms can take this opportunity to review common journeys to identify when and where customers or even employees get hung up or are likely to abandon a process and find ways to improve.  

Solving for common pain points is also an opportunity to boost customer satisfaction and retention. In an uncertain economy, customer trust is more important than ever – and can become a key differentiator as consumers tighten their purse strings and approach new products and investments warily.  

FCA Compliance in Practice Across Financial Services 

Let’s take a closer look at Consumer Duty by considering three use cases where clear communication is essential to allow customers to make informed choices. 

Lending Communications 

To ensure positive lending experiences, banks need to make it easy for customers to understand the cost of credit. That means providing total transparency into interest rates, fees and penalties, and clear guidance on how to complete processes such as closing an account or paying off a loan. All customer communications must be consistent and accessible to facilitate informed decision making. 

One roadblock to achieving streamlined lending transactions is disparate communication streams which limit visibility, introduce the chance of costly errors and increase compliance risks. Using a cloud-based communication platform that’s integrated with core systems like CRM and other data sources is important for breaking down internal silos and ensures a single source of truth for a unified approach to agreements. By applying the directives of Consumer Duty, banks can offer customers clearer access to the capital they need. 

Communicating About Investing Risks 

FCA compliance with Consumer Duty also compels wealth management companies to improve transparency in how they communicate with investors; firms must disclose advisor incentives up front as well as potential risks. They need to make it easier to engage, for example enabling clients to complete risk assessment interviews over digital channels instead of blank fillable PDF or web forms. 

Further, as clients increasingly expect advisor availability across multiple channels and time zones, organizations will need to adapt to deliver on Consumer Duty’s customer support requirements. By embracing two-way, digital-first conversations, wealth management companies can steer clients toward gainful investments no matter where they are. 

Insurance Interactions Made Easier 

Consumer Duty will shift the pension and life insurance industry toward greater customer-centricity as firms are required to make their products easier to understand and use. In the realm of claims in particular, insurers will have to show urgency, empathy and proactiveness in the way they communicate. Digital-first technologies like AI, automation and omnichannel communication delivery can help bring policyholders the efficiency, speed and service consumers deserve. 

Three Ways Smart Communications Can Help with FCA Compliance 

Smart Communications can help your organization comply with Consumer Duty by simplifying and automating customer conversations across every channel.  

First, our forms automation software enables you to turn static, paper- or PDF-based forms into dynamic, two-way digital conversations powered by data in your core system. By eliminating unnecessary questions and complex if/then statements, it’s easier for customers to understand what they’re signing up for. In addition, pulling customer data from connected systems reduces the effort required to fill out applications for loans, credit cards and other products, while also increasing accuracy. Forms automation also supports the need to deliver better digital and mobile self-service, so customers can stop and start processes on different devices for added convenience. 

Next, our SmartCOMM™ customer communications management (CCM) platform enables you to centralize and manage all of their customer communications for greater visibility and transparency across every line of business. Using business rules, you can deliver across any channel, from digital to print, with just a single template. In addition, SmartCOMM provides an audit trail detailing when communications were changed, what was changed, and by whom, to enable reporting for the FCA or other regulators. 

Finally, our built-in content intelligence capabilities mean that you can gain true insight into the effectiveness of both communications and forms processes. Understand where customers are getting stuck in an interview, where questions or processes can be improved, and how to enhance customer communications across the lifecycle. With our Content Intelligence module you can evaluate the readability, sentiment and tone of communications to make sure they are both empathetic and effective.  

Compliance with FCA Consumer Duty: An Opportunity in Disguise 

While the FCA’s Consumer Duty rules only apply to firms serving customers in the U.K., it’s part of a global movement by regulators towards increasing consumer protections in financial services—one that’s also being advanced in the U.S. No matter where in the world your business operates, it’s time to improve customer communications and add transparency to product offerings. It’s time to put customers first.  

Given the constantly changing requirements in financial services, insurance and other highly regulated industries, compliance teams need the ability to manage and monitor changes to customer communications. Adopting an agile, cloud-based CCM platform alongside a forms automation solution will allow firms to provide consumers with clear, consistent, accessible information to make better decisions. That’s good for the consumer, and the business.  

Ready to discuss your compliance challenges and how Smart Communications can help you mitigate risk? Let’s Talk! 

3 Ways a Better Digital Forms Experience Helps Health Payers Increase Star Ratings

This is an image of an elderly woman sitting in a wheelchair using a digital tablet.

 
 
 
 
 
 
 
 
 
 
 
 

By: John Zimmerer, Vice President of Healthcare Marketing at Smart Communications

Star Ratings are a critical aspect for customers when evaluating health insurance plans as they help consumers make informed decisions about their health coverage. To increase enrollments, insurers should strive to keep their Star Rating above a 4.0, but they also need to think about the existing customers they serve. That means enhancing the overall customer experience and increasing customer loyalty, sometimes a tough ask with constantly shifting regulations and the need to accelerate digital transformation weighing on organizations. 

In this article, we talk about how insurers can increase their Star Ratings by focusing on one of the top contributors to the overall customer experience: communications. To provide excellent communications across all channels where members interact with the business, health insurers need to help members feel seen and known as individuals. This starts with developing a strong customer communications strategy, made possible by leveraging pure cloud CCM solutions. As part of that communications strategy, insurers also need the proper forms solutions to gather member data and put it into action while ensuring they’re compliant and secure. Keep reading to learn the three ways a better digital forms experience helps to increase Star Ratings and customer loyalty, but first, we’ll touch on why Star Ratings matter. 

Why are Star Ratings Important for Health Insurers? 

  • Measures quality of care: Based on various factors—such as preventive care, patient experience and medical outcomes—Star Ratings give consumers a comprehensive picture of the plan’s performance. This information can help consumers choose the best plan for their needs and ensure they receive quality care. 
  • Promotes competition: Star Ratings create competition among health insurance providers, encouraging them to improve their services and invest in the systems and processes that help them support their members. As a result, members benefit from a wider range of high-quality options and can choose the plan that best fits their needs. 
  • Improves transparency: The ratings provide a clear, unbiased assessment of the quality of benefits and services offered by health insurance plans, which can help consumers compare plans and make better-informed decisions about their health coverage. 
  • Supports evidence-based decision making: Star Ratings are based on data, including patient surveys and medical records, which helps to ensure that the ratings are accurate and factual. This data-driven approach supports evidence-based decision making and helps consumers choose the best plan for their needs, an especially important factor considering the growing digital native cohort who’ve become accustomed to making decisions quickly. 

YOU MIGHT ALSO LIKE | ‘4 Ways Forms Automation Can Enhance the Healthcare Member Experience‘ 

1. Digital Forms Can Help Address This Customer Driver Behind CX and Loyalty 

As of 2023, Star Ratings have become more impacted by customer experience (CX) with member experience metrics making up 57% of Star Ratings for Medicare Advantage plans. Considering 1 in 3 customers will leave a brand they love after just one bad experience, it’s critical to avoid situations that can lead to this. With that said, effective customer communications management is key to providing a positive customer experience. Health insurers should aim to provide clear and concise information about their plans, including claim-related communications. The requirement to provide personalized communications, tailored to the individual member’s needs, also extends to forms processes. 

For example, claims appeals can become tricky when using traditional methods of communicating between a member and the payer. When questions arise, members are typically instructed to contact a call center and find, fill out and submit a generic appeal form to request redetermination. This multi-step approach increases the customer effort (another factor that impacts Star Ratings) and ultimately leads to frustration. However, this form is an important piece of information during the redetermination process and can’t be overlooked.  

Using a digital forms solution, on the other hand, allows members to engage in an intelligent interview that provides a guided experience. A link to the interview can be embedded directly into the Explanation of Benefits (EOB). After submitting their responses to the interview, members can download a copy of the appeal form for their records. By integrating the interview with core systems, an Appeals and Grievances staff member can be notified of the submission and start the review process. This allows insurers to provide members with a self-service option and save time and money by removing steps related to receiving, scanning and routing paper forms. 

This is a quote: "Did you know? Providing personalized communications, tailored to the individual customer's needs, requires a sophisticated forms automation solution that digitizes, optimizes and modernizes forms processes across the healthcare member experience."

2. Build Loyalty by Helping Customers Understand Their Plans 

Health insurance can be a confusing and complicated topic for many consumers. With many different plans and options available, it can be difficult to understand exactly what is covered under a particular policy and what out-of-pocket costs might be incurred. However, health insurers can build loyalty by helping their customers understand their health plans and making the process of navigating the healthcare system easier. 

One way to do so is by providing clear and concise information about the different aspects of a health plan. This might include easy-to-understand descriptions of coverage options, deductibles, copays and other terms that are commonly used in the healthcare industry. By providing this information in a format that is easy to understand, payers can help customers feel more confident in their decision-making and more comfortable with the choices they have made. This enhances the overall member experience, thus, increasing loyalty and customer retention. 

In addition to providing clear information about the details of a health plan, health insurers can also help their customers understand the broader healthcare system. For example, they can offer resources and tools that explain how to find a doctor, how to schedule appointments and how to access other benefits. By offering this type of support, customers will feel more empowered and in control of their healthcare experience, including having more options to easily self-serve when necessary. 

Offering personalized support and guidance will require the right systems and processes in place, like SmartIQ™, a sophisticated digital forms solution. Providing this type of personalization, health insurers ensure customers feel heard and valued, and can establish a deeper connection with their members. Straightforward information about the costs of healthcare services, and clear explanations about any restrictions or limits on coverage, will help build trust and establish a strong relationship with their customers. 

RELATED READING | ‘Work SMARTER, Not Harder: Enhancing CCM Efforts with Forms Automation‘ 

3. Create a User-Friendly, Digital Forms Experience

The member’s experience with forms is measured by the CAHPS surveys and translates to the customer service metric in the Stars Rating. When providing interacting with a health-related form, everything from which colors are used to font sizes and the information architecture influence a member’s perception of the brand. All are also key factors in creating user-friendly forms experience. But, how do health insurers know what to look for when creating responsive and user-friendly digital forms that elicit a positive response from members? The good news is, a pure cloud forms solution enables organizations to create a truly responsive forms experience, meaning it will look and operate the same across all platforms and channels. A few things to keep in mind: 

  • Use what you know. Leverage integrations with core systems and single sign-on to pull data into forms so that members can review and revise rather than rekey this information. This will reduce the member’s effort as well as the opportunity for data entry errors. 
  • Make the form visually appealing. Use a clean and organized layout, including clear headings/subheadings, helping customers quickly find the information they need. Consider using colors and images to make the form more appealing and easier to navigate. 
  • Keep it simple and straightforward. Avoid using technical terms/jargon that may be confusing or misleading to customers. If specific terminology must be used, be sure to provide clear explanations of any terms that may be unfamiliar to customers. This includes using help text in the form. 
  • Make the form accessible. Ensure all digital forms are accessible to customers with disabilities; this isn’t simply a nice-to-have, it’s a must-have, given 508 compliance mandates. Use appropriate formatting, like larger text/high-contrast colors, and include alternative text descriptions for images. We offer a guide to help make SmartIQ interviews WCAG-compliant. 
  • Validate information in real-time. Use real-time validation to alert customers of any errors or missing information as they complete the form. This helps reduce the risk of errors and ensure that the form is completed correctly the first time, diminishing the chance for customer frustration and/or eliminate delays. 

The above list is not exhaustive by any means but it’s important not to overlook this key point to enhancing star ratings and customer loyalty. In fact, 60% of customers will abandon a form if the process is too difficult—something that could be mitigated by deploying modern forms that are easy to engage with. The right vendor partnership will help insurers optimize the systems and processes they use to interact with customers, including the user-friendliness of their forms experiences.  

If you’d like more information on Star Ratings, customer experience and how to enhance member loyalty, watch the webinar recording of ‘Latest Benchmarks & Top Priorities for Health Payers’ featuring Judy Weader from Forrester Research. If you’re ready to take your health insurance organization to the next level.