Eavan Garvey, Head of Group Conduct Risk, Bank of Ireland.
How is the work to improve conduct and culture impacting financial services firms?
- Reduced cost from conduct risk that has crystallised. The cost of conduct issues is significant; while the actual amount of remediation and the enforcement penalties are likely to account for the bulk of costs, other costs such as staff, printing, postage, buildings, etc can also be considerable.
- Customer retention. Where a firm has values that place the customer at the core, and where these values can be seen in everything the firm does from the development of new products, to how the products are advertised and the managing of complaints, thus demonstrating that the firm has the customer truly at its heart, the customer is more likely to have an increased confidence in the firm and is more likely to stay with the firm and avail of additional products or services provided by the firm.
- Positive reputational impact. Where the firm’s strategy is clear and where it can easily be seen how it fully aligns with the firm’s approach to customer outcomes. In addition to customers being more likely to stay, the firm has an improved relationship with third parties including regulators, policy makers, media, etc increases market confidence.
- Simplified product proposition. A truly customer centric firm will support a product proposition that is less complex, easier to understand, with terms that are not designed to create cumbersome conditions that are difficult to understand. Such a firm will also have systems that are likely to support the proper maintenance and servicing of products, and will instill confidence in the market as any likelihood of remediation is reduced or removed.
- Less complaints/errors. A firm is likely to have a reduced volume of complaints where conduct risk has been fully embedded. Similarly, where a firm is fully focused on embedding good conduct outcomes, the number of complaints being escalated to the ombudsman are likely to be reduced as the complaint outcome will be fully focused on what is in the best interest for the customer. Consequently, reputational risk will be reduced.
- Staff are more likely to be engaged as products are simpler to understand, easier to explain to customers, processes are less complicated and driven primarily by systems rather than manual intervention. Customers are happier with the product proposition and service, and are less likely to complain.
- Sustainable long term solutions. The firm’s strategy is more sustainable as it is focused on embedding long term sustainable solutions. Regulators are keen to understand that a firm’s strategic plans are fully aligned to customer values, thus ensuring that the strategy is more sustainable.
What are the best ways to encourage staff to engage with the conduct agenda in their day-to-day activities?
In addition to consumer protection, conduct risk can be described as a focus on the corporate culture and the ethical behaviour of employees and management in a firm. To successfully embed an ethical culture across a firm, conduct risk culture must first be supported and implemented by senior management and board members. Regulators have regularly linked the competence and ability of staff to some of the well-known remediation issues. Regulators are looking to firms to evidence the link between appropriate culture, adequate training and managing the risks that a firm’s particular business model represents.
Training is a critically important element of the conduct risk framework. If staff do not understand what or how to embed good customer outcomes, in addition to why it is important to maintain the integrity of the market, behaviours will never change. With this in mind, and as training is particularly important, it is critical that this is right from the outset. Training should consider how to develop staff behaviours in addition to providing technical knowledge in relation to the various components of the conduct risk framework, in particular the conduct risk policies.
What are the keys to delivering high quality products and services, and a great user experience, while maintaining a robust conduct agenda?
“Provider firms will be expected to have robust procedures to assess their target market, perform adequate stress testing, and manage the product risks for consumers. We would expect the sorts of standards that consumers associate with basic vehicle safety or over‑the-counter medicines, for example, to be the norm for widely sold financial products. Firms should also consider making their own pre‑approval processes more transparent; the aim should be to increase the level of trust consumers have in financial products.” Martin Wheatley – Journey to the FCA
When developing products firms should consider:
- whether the product can meet customer needs
- whether there are any unfair terms
- whether documentation detailing the product is clear and easy to understand
- whether the product is overly complex
- who should be the target market
- marketing and advertisements must describe the product or service in a clear, fair and not misleading way, to help the customer avoid poor purchase decisions
How is the ever-increasing level of digitisation impacting conduct risk management?
Regulators encourage innovation in the best interests of consumers. In particular, technology and product innovation can enhance competition and customer choice. There is however a need to focus on fair consumer outcomes, for example when considering provision of financial advice through on-line channels. Where firms are moving more to providing financial advice and recommendations through on-line channels they must ensure that the necessary protections are in place to deliver the right consumer outcomes. Firms must consider the following:
- The appropriateness of selling all products online and whether certain more complex products should only be sold with an advisor.
- How customers including more vulnerable customers are not financially excluded where the overall strategy is to move towards online platforms.
- Consumers tend to focus on headline information when buying online, firms must ensure key information in relation to the features and risks is available and displayed in a manner easily identifiable and understood to all customers. Regulators refer to the ‘Framing’ effect which describes how different consumer choices can be made depending on how information is set out. Firms can present the same information in different ways and this can lead to different choices by consumers. For example, certain pieces of information may be more prominent on a web site then others resulting in certain biases being prompted. Firms can benefit from ‘framing’ where they have deliberately created complicated pricing structures, where key information is masked by including some irrelevant information or where the information can induce an emotional response.
- Whether robust systems are in place to deliver a reliable service to customers. While technology does and will continue in the future to form a part of many firms’ growth and development strategies, firms will become more vulnerable due to dependencies on underlying systems, and the substantive operational risk this can cause. An over reliance on technology-based infrastructures can create additional risks from systems used outside financial markets such as mobile phone providers.
What are the most powerful ways that firms can improve their conduct agendas (getting buy-in from staff / improving systems and processes / developing better risk models, etc.)?
To improve the conduct agenda, it is critically important that firms get buy in from the board and staff. The firms board and senior management can be comfortable that the conduct risk strategy is robust and sustainable and that there are benefits to the firm:
- from a business sense – it makes good business as the business model becomes sustainable with little customer complaints reduced cost as a result of less crystallised conduct risk, this is obviously a benefit to the firm as well as its shareholders;
- from a moral and ethical sense – that firms do things because they should, not simply because they can.
Why will you be speaking at ECN’s Conduct Risk Summit, and what do you hope to get out of the event?
This is an area that I am hugely passionate about. I really believe that when firms are truly customer centric they will reap rewards not only in the context of customer satisfaction, but also in the behaviours and values espoused by staff and senior management across the firm. I believe this message and the meaning of conduct risk has been overly complicated over the last number of years, and I would like to show this is not such a complex risk, and that measures can be easily implemented to reduce the crystallisation of conduct risk issues.