Memo to the board

Adam Samuel drafts a template communication to directors about inadequate resourcing for complaint handling.

Adam Samuel BA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted at AdamSamuel@aol.com. His book, ‘Complaints and Compensation: a Guide to the Financial Services Market’, is available from his website, www.adamsamuel.com.

The following scenario came up at a recent complaint handling event that is becoming all too common. The company is for sale. It is receiving the same number of complaints as the previous year of broadly similar difficulty. Staffing numbers, though, have been halved (both in terms of numbers and experience). There is also management pressure on the complaints team to bring the compensation payments down. One experienced complaint handler suggested with a wry smile that one could wait till a complete breakdown in the complaint function occurred, which would force the board to sort out the problem. While worryingly, this might be the ultimate solution, there seemed to be another way. This essentially consisted of setting out the precise compliance position for the board in a report. It might take this form with appropriate adaptations to meet the facts of the situation: