FCA Consumer Duty compliance and delivering good customer outcomes at Perch Group

Perch Group’s Chief Risk & Customer Officer Simon Unsworth was asked by Credit Services Association (CSA), the UK trade body for the debt purchase and collections sector, to contribute an essay to its paper entitled ‘From Policy to Practice: Implementing Consumer Duty in the Collections Sector’.

The collection of essays from CSA member firms explores their experiences in the first year of the new regulation. Simon’s contribution is below:

Since its introduction, Perch Group has significantly invested in Consumer Duty compliance, building on its existing customer centric culture and ‘treating customers fairly’ (TCF) foundations. From early horizon risk scanning through to the implementation date in July 2023, the Group Risk & Compliance team, has implemented a robust implementation plan across the business, under the watchful eye of the Board, and with the support and challenge from a specifically appointed Non-Executive Consumer Duty champion. We also utilised specialist third party support in Addleshaw Goddard to guide us on our initial plans and later partnered with Investors in Customers (IIC) to review progress at the midway point and to assess the customer experience being delivered.

Through rigorous training and adherence to industry best practices, Perch places a strong emphasis on transparency and communication, providing clear and comprehensive information, signposting to sources of free and impartial debt help or other useful sources of information or support; and by working collaboratively with our customers Perch can develop tailored repayment solutions that prioritise affordability and sustainability and provide help and support that align with our customers circumstances and needs; providing a positive impact on their financial well-being.

Following the implementation date in July 2023, we continue to refine our systems, policies, processes, MI, and controls, as we constantly strive to enhance the customer experience. We routinely monitor and measure customer outcomes as part of our overall performance view and proactively seek out opportunities to continuously improve and provide added value. Our low complaint uphold rate and Excellent Trustpilot rating are just two examples of metrics that we use, and that we’re extremely proud of.

As we approach the final implementation milestones, we’re proactively circling back on the FCA’s Dear CEO Letters to the debt purchase and collections sectors of 2021 and 2023 and the FCA’s more recent Consumer Duty guidance to check the actions taken first time round were adequate and effective, and to reassess our standards and ensure we continue to deliver good customer outcomes across the key areas of focus.

We’re also refreshing our training and working to further embed understanding and ownership in the first line operation and in all business areas wider than the second line Risk and Compliance function, we’re conducting a Closed Product risk assessment. We’re also planning to have a Consumer Duty audit conducted by a reputable third party company to provide independent assurance to the Executive team as part of the requirement to produce a report to the Board upon the anniversary of the Duty.

At Perch Group, providing good customer outcomes is not just a regulatory requirement, it’s a strategic and cultural obsession.