Overview
The client had historical issues around the mis-sale of Payment Protection Insurance (PPI) and was under strong pressure from the regulator with regards remediation.
The Challenge
Following an FCA request for information on the Bank’s work and analysis conducted into the mis-selling of PPI, it needed to review sales across all channels and validate any potential detriment to customers.
As a result of regulator intervention, and in-line with its peers, the Bank had commenced a Root Cause Analysis of its historic PPI sales practices with a view to taking further action.
The Solution
Novo Altum provided a small but experienced team to help establish the review of PPI sales and assess the further action required.
The team conducted a Root Cause Analysis by sales channel, taking into account evidence including:
• Sales documentation
• Training materials
• Incentives schemes
• Existing complaints
• FOS outcomes
• Declined claims
• Staff interviews
• Call recordings
• Business-as-usual policies and procedures
• Compliance monitoring reports
• Regulator correspondence
The findings and observations were matched against the FCA’s DISP and PS 10/12 guidelines using a heat map RAG status approach.
The RCA review established treatment consideration cohorts which informed the journey for remediation. Novo Altum then commenced support of remediation workstreams.
Results
The team provided a framework for the Bank to assess and quantify the volume of remediation required. They then established the approach for remediation and supported the Bank in data analysis, automation of access to the data and setting up the customer letter process.
This provided the Bank with a much clearer view of its situation and the volume of work it needed to undertake.
