Conduct risk remediation

Deliver good customer outcomes with speed and accuracy to restore Regulator confidence and reduce the cost of conduct & remediation

The macro-environment in the UK and Financial Services industry is increasing the focus and complexity of conduct and remediation, due to the following key factors:

Rising conduct regulatory pressure, in particular with the increased standard of Consumer Duty;
Increasing financial distress and customer vulnerability due to the Cost-of-Living crisis; and
Heightening consumer expectation in an increasingly competitive market.

A successful remediation is of strategic importance as trust is restored and good outcomes are delivered to customers. Our collaborative approach starts with agreeing the right customer treatment strategy and desired remediation outcomes up front, defining the critical success factors and key performance indicators and effectively mobilising operations to deliver good customer outcomes on time and with quality. You can be assured that your customers are in a safe pair of hands with KPMG.

We can help you face your conduct and remediation challenges head on, executing with speed and accuracy, on large scale or smaller targeted remediations. Our solutions bring together best in class technology to drive automation, reduce costs, and improve time efficiencies, leveraging our regulatory and operational expertise to achieve quality and consistency, whilst ensuring a positive customer experience.

Chris Steele

Partner, Banking Risk and Regulation

KPMG in the UK

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What we do and how we do it

Our solutions can be applied to both current and historic issues requiring resolution. We also support clients in considering future regulatory preventative activities and building in-house remediation capability. With scalable options, we support firms of all sizes.

We take a holistic approach to remediation and follow three key steps, bringing together our:

We know the importance of a right first-time approach to deliver good customer outcomes within the right timeframe and at the right cost. We have a tried and tested methodology to stand up remediation programmes for success to provide stakeholder and consumer confidence:

Root cause analysis and Population ID

By completing thorough root cause analysis we can ensure the correct identification of the impacted population and create effective cohorts to improve operational efficiency and the quality of outcomes.
Pilot and Refinement

Prior to standing up the full remediation programme, our team will proactively check and challenge the population, policy and methodology, and customer outcomes through a rigorous test and learn activity. This allows our team to strengthen the planning, refine the population and extrapolate more meaningful insight into how many cases are likely to be in scope for the full remediation programme, and what potential redress amounts would be payable based on the cases found in the pilot sample.
Governance & Planning

Our remediation governance framework ensures transparency, control and effective oversight of the programme and operation. We have highly experienced project managers who understand the challenges of remediation and are proactive in planning and governing progress to provide stakeholder confidence.
Measures of Success

The key to a successful remediation programme is understanding and defining what success looks like right at the start. We have developed robust measures of success, including operational throughput, customer engagement and quality outcomes, and these can be reported on an ongoing basis to provide focus to the programme and operational teams.

We can support you through operational execution with a range of expertise and technology accelerators:

Regulatory Subject Matter Experts

Our Regulatory Subject Matter Experts understand the regulatory expectations and know what good customer outcomes look like. They can provide confidence to internal and external stakeholders and can be embedded within your operation to provide coaching, training, and case specific support.
Operational and Programme Management support

We have transformation teams experienced in delivering conduct and remediation programmes. They are experts in providing operational excellence and programme management support, including governance, process design/improvement, operational ways of working and detailed operational resource planning.
Skilled and experienced case handling resources

Our KPMG Conduct and Remediation Academy are skilled in all aspects of remediation case handling, complaint handling and customer engagement. Experienced team leaders and operational managers ensure high quality case outcomes and an efficient operation. Our rigorous selection process ensures that the Academy recruit high quality KPMG colleagues focused on delivering good customer outcomes and a great customer experience. The KPMG Conduct and Remediation Academy are trained by our highly skilled Regulatory SMEs, undertake qualifications (CeMAP) and are experienced in delivering large-scale, complex remediation and complaint programmes. Additionally, we have a strong network of skilled and trusted Conduct and Remediation Associates which includes skilled complaints handlers, QC and team leaders
Technology accelerators
By combining KPMG’s Regulatory, technology and operational expertise, we have developed several technology-enabled assets to automate the remediation life cycle, drive operational efficiencies and reduce cost. Our technology accelerators include:
1. Automation through an AI led decisioning tool that supports effective triage and allocation of cases across the operation
2. Automated letter generation, utilising standardised templates, branding and terminology to improve quality and efficiency
3. Remediation workflow tool – our cloud-based workflow has been designed by our remediation experts and provides case management and reporting to deliver control and visibility of operational progress and performance.
4. Redress calculators can be customised for low/high volume and simple/complex calculations.
5. Our automated QC/QA tool, KPMG Decipher, transforms the customer experience, improves operational effectiveness, and supports robust risk management, through intelligent automation.

When closing the programme, our team will undertake key activities to instil confidence that the right outcomes have been delivered across the programme. They will provide a detailed closure report which includes how the agreed objectives and success factors were achieved, what processes and operations have been implemented and any future recommendations, which can easily be distributed to your board and the Regulator. Our closure activities include a detailed analysis of the policy and process, documented customer outcomes and data analysis to provide end to end traceability from the original population through to outcomes and completion.

Key benefits of our solution

Good customer outcomes

We understand the Regulator’s expectations and how firms must think more widely about their customer journey. We can help clients deliver good outcomes and an improved customer experience through effective operations, technology, and our subject matter expertise.

Speed

We understand the need for rapid and controlled delivery, and can mobilise operations to tight timescales, and deliver ‘out of the box’ technology solutions which can be tailored to your needs.

Experienced resource

Qualified and experienced individuals from our Regulatory, Transformation and Operational teams, combined with our Conduct and Remediation Academy, and our Conduct and Remediation Associate Network can provide support by augmenting your existing teams or through an outsourced operation.

Regulatory compliance and assurance

Regulatory subject matter experts who have worked on many rectifications and S166s and can support you in dealing with vulnerable customers, complex populations, and your customer treatment strategy. Through their working relationship with the Regulator, our team can help you to interpret FCA requirements and ensure you demonstrate the right level of evidence to support good customer outcomes.

Quality

Quality is at the heart of our proposition. We leverage our Quality framework, coaching and training methodologies in collaboration with tools and technology to ensure high right-first-time quality scores and good customer outcomes.

Leading technology

We bring a suite of leading technology accelerators including our AI decisioning tool, automated QA, workflow, and redress calculators, which can be used as individual components or as part of an outsourced operation.

Key areas where we can provide expertise include:

Regulatory / conduct programme management and transformation
Product mis-selling investigation (pensions, insurance, investments, mortgages)
Product led-remediations
Legacy product closures
Closure/off boarding (non CDD)
Complaint resolution and customer treatment
Technology/calculations or System Driven/Service breakdowns
Programme assurance
Quality assurance
Population analytics, including scope analysis and outcome mapping (data waterfall assurance)
S166s [Skilled Person reviews and support for your team to deliver a S166]
Complaints handling
Redress calculators
Population testing and assurance

Our consulting insights

Five design principles to foster successful remediation

White paper discussing the changing landscape of the remediation challenge that Banks face and key design principles to carry out successful remediation activity to combat these challenges.

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