We see these examples as a way of helping you think for yourself about how best to meet our high-level requirements within your business. And, by reading about real-life examples of practice on either side of the minimum standard, you can see how to draw a line in your business on what is and is not acceptable.

Management behaviours

Good practice

1. Firm's gap analysis identified that its policy on mid-term cancellations was unfair. Management decided it would be fairer to charge a flat fee for cancellations which is disclosed upfront to its customers.
2. Management became aware of a flood of complaints about a provider and its poor customer service in handling claims. It took a proactive approach and moved business away from the provider, contacting each customer with an explanation.

Poor practice

1. Management not monitoring sales because it felt advisers were very experienced and did not need monitoring.
2. Management did not react to a potential risk arising from its postal business. The firm noticed that most customers returned their terms of business letter (TOB) to the firm with other documentation. The firm did not improve its covering letter to make it clearer that it is important and the customer should keep it.
3. Management engaged compliance consultants but failed to act on the advice given.

Sales and advice

Good practice

1. A robust renewal process in place to ensure that the firm contacts customers ahead of renewal to check for any changes in circumstances. Each policy is re-brokered every year to ensure the customer has the best deal.
2. Management challenged providers on the unfairness of the wording of system-generated policy documents.
3. The demands and needs statement has been reviewed and unnecessary jargon removed.

Poor practice

1. Inadequate know-your-customer (KYC) information regarding eligibility and the suitability of payment protection insurance sales.
2. Advisers not trained on the firm's full product range resulting, in customers being recommended a product from a limited range.

Complaints handling

Good practice

1. Firm conducted in-depth root-cause analysis of complaints and created a log of lessons learned from each complaint.
2. Firm contacted customers after resolving their complaint to get feedback on how to improve their service.

Poor practice

Insufficient complaint handling procedures. Management felt their only obligation was to point out to customers what they needed to do if they had a complaint. Staff had not been trained or were unaware of what constituted a complaint, which meant that complaints had been received, and but not acted upon. Other firms could not see the point of having written complaint procedures if they hadn't received a complaint.