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In Focus Collections

Left-right: Jerome Heap; Laura Bennett; Stuart Ashcroft; Kathy Cox; Mike Harfield

thing to do for our customers. So we are starting to move towards their standards, and what they would want us to do, so that we are one step ahead. From a corporate responsibility point of

view, you can at least show your customers that you are doing the right things in terms of collections. This fits quite nicely into the vulnerability side of things as well.

SA: I do not anticipate that the FCA are going to regulate matters that they do not have a mandate to do so. It is not in their interests because they have a big enough task in worrying about all the businesses that do come within their remit. But the pressure is more indirect, in that the regulators in this space – OFGEM, OFWAT and so on – are seeing the FCA as an expert on debt and so are pointing some of their guidance toward the FCA’s guidance. If you are using third parties, more often

than not they will be using practices that are regulated by the FCA because most third parties are FCA-regulated and will choose to used standardised practices for both regulated and non-regulated debt. And the customers are now also used to dealing with people who are talking to them, assessing affordability, and accepting payment plans that are consistent with that – if you go away from that, the chances are that they will raise complaints or wonder what is going on.

KR: I think that OFGEM were ahead of the game on things like vulnerability, so, for us, these are not new things that are putting added pressure on us – we have that pressure already. We have a lot of controls around how we identify and deal with vulnerable

October 2015

customers, even to the extent of segmenting different types of vulnerable customers – vulnerability is not always permanent, a broken leg is not the same as a mental illness; there is a lot of work that we have done for

SA: I doubt that there is an organisation, at least in the regulated space, that continues to reward entirely on cash collected.

People are fairly open, but that is once you have the conversation going – in fact, once you have the conversation going, you are 90% of the way there

a long time. OFGEM is very focused on the customer experience being a good one.

How have expectations on collectors developed in this period? MW:We have changed our recruitment approach when looking for new people – some of the more established staff had difficulty moving away from the more traditional debt-recovery approach at first; we have spent a lot of time training and supporting them. I think we are broadly there now and if you have a healthy turnover of staff, that helps, as does the regulatory guidance issued by the FCA.

LB: Now it is about training staff to listen and understand, not about getting full payment or setting something up if it will only fail after the first month. Then there is a need to follow up afterwards to see if the customer is happy.

LB:We are really conscious that often even a small percentage shift in behaviours is highly valuable and you can achieve that with some relatively low-cost changes to correspondence going out, for example by hand-writing envelopes.

PS: There have been big changes in the world of enforcement, in the structure that we follow when we enforce any debt and being encouraged much more to go to a compliance-based model. It is all about engagement: agents will go

to properties, they are there to try to get that person to engage and to get that person to enter – even at that late stage – into some kind of payment arrangement. We have to incentivise agents, but we

have to incentivise them in the right way and there have been a lot of changes in terms of the pressures that we are under in all of the market sectors to demonstrate that we are driving more of a compliance process. At the end of the day, clients’ reputation

and any potential damage to their reputation is a big factor. We have to make sure that everything we do tries to protect that reputation as well as achieve that outcome.

RH: In terms of enforcement, certainly in the domestic market today, it is much more about engagement. We are now using firms to go out and do an initial social visit to knock on the door and say ‘how can we help?’. CCR


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