Call monitoring – is it worth it?
Call monitoring is the recording, retaining and reviewing of the interactions you have with your customers. Many consumer credit firms are finding the ability to review customer calls at a later date delivers significant benefits in improving the way customers are treated. This is particularly true for those who are newly authorised. Some however are asking is it worth the time and effort to embed call monitoring as a routine part of their business processes.
The FCA already recognises the value of call monitoring; up until January this year, many financial services firms including banks and investment houses were required to record all customer calls under the Conduct of Business Sourcebook (COBS) 11.8. Although the implementation of MIFID II led to the removal of COBS 11.8, and the restriction of mandatory call recording requirements to a smaller percentage of firms, this does not mean that other businesses should disregard call monitoring all together. As the FCA has said on many occasions, good conduct and compliance is as much about what firms should do, not just what they must do to meet the bare minimum.
Fundamentally, call recording and reviewing forms part of an effective compliance monitoring framework. Being able to review the interactions employees have with customers can provide early indicators of non-compliance, for example poor sales practices. Early risk indicators allow businesses to remediate issues quickly, and to mitigate the risk of costly complaints or FOS referrals. Where complaints do arise, access to call recordings can support speedy and effective dispute resolution.
Firms who wish to put good customer outcomes at the heart of their businesses should consider the way call monitoring can foster good customer relationships and encourage customer-focused behaviours. Call monitoring provides excellent evidence of a firms’ commitment to the Treating Customers Fairly (TCF) principles. As well as providing early risk indicators, call monitoring can also be used to reinforce positive behaviours and to support TCF-focused incentive and remuneration structures.
Firms who are apprehensive with regards to additional expenditure and scalability issues should not be unduly concerned; developing technology including VOIP and other hosted telephony solutions keep the associated costs low. Call recording capability actually allows some compliance monitoring, including quality assurance and outcome testing to be outsourced to experts such as CCAS. This provides significant peace of mind, independent verification that operations are compliant, and for smaller firms, eliminates the need to employ a full-time internal compliance function. This may result in a reduced compliance bill overall.
Learning lessons from other regulated firms, poor record keeping has traditionally been an area of concern for the FCA. Retaining a record of calls is an excellent way to evidence good and compliant operations in times of increased regulatory scrutiny. Where the regulator has concerns about a specific issue and a firm cannot prove that no customer detriment occurred, the FCA may err on the side of caution and order costly a costly remediation exercise which can also inflict significant reputational damage. If your record keeping is not up to scratch, you may only be able to appease the regulator by remediating a much larger cohort of customers than actually experienced any detriment.
Contact us to discuss how can CCAS can help your firm benefit from introducing call recording and monitoring, or to make the most of your current capabilities through external quality assurance and validation.