Speaking as he introduced the Mortgage Forbearance Webinars, which are being used to help firms prepare for the next phase of supporting mortgage customers through the pandemic, Jonathan Davidson (Executive Director of Supervision – Retail and Authorisations) set out the FCA’s expectation of how firms should be delivering positive outcomes for customers.
The focus comes at the point a significant number of customers will be coming to the end of an agreed payment deferral, with the FCA’s data showing that most mortgage deferrals have now expired. In the FCA’s perspective, this seemed to signal a shift in approach, with ‘crisis support’ moving towards ‘tailored support’ for the individual.
However, they have cautioned about moving headlong into ‘business as usual’ due to the absence of clarity on what the new environment looks like, acknowledging many borrowers will be facing a loss of income, over differing durations, and solutions may need to reviewed regularly as their circumstances change.
Other key areas highlighted were:
- Outcomes need to be right for individual borrowers rather than “one size fits all solutions”.
- Operational challenges remain and there needs to be continued focus on how firms resource, train, assess, monitor, and mentor customer-supporting functions. Management of staff working remotely in a demanding job supporting customers in financial distress requires special care.
- Ensuring appropriate oversight of third-party firms you are outsourcing customer impacting services to.
- The sheer number of borrowers needing help in a short period of time may require automated solutions. However, hands on support should be available and clearly communicated to those that need it and customers on an automated journey need to understand the implications of what they are agreeing to.
- Outcomes need to be monitored to ensure that, where issues occur, the customer does not experience a detrimental result.
- Customer vulnerability needs to be identified and acted on.
Significantly, over the coming months, the FCA will be looking at how your firms have adapted to the challenges, and the outcomes received by consumers through supervisory ‘multi-firm’ work. To assist firms in assessing whether they have met FCA expectations, FourthLine’s Consulting team has produced toolkits for both the FCA’s Temporary and Additional Coronavirus for Firms, downloadable from the following links:
For any support needs you may have around meeting the FCA’s expectations around Coronavirus measures taken, feel free to contact our Consulting team