We were engaged following a negative audit which indicated that some treatment of arrears cases for mortgage customers had been incorrect and potential detriment caused to customers.
Our first phase was to investigate further the outcomes of the audit and to validate whether there was a problem, the populations affected and the possible scale and nature of potential redress. We did this through reviewing a sample of arrears cases and reviewing the arrears management policy, processes and treatments employed. We established a case review methodology which was agreed with both the bank and the regulator.
Following, this review, we provided detailed scope and methodology for a Past Book Review (PBR) covering circa 6,000 arrears cases in specific populations (our team consisted of circa 40 senior mortgage case reviewers together with relevant programme management staff). We were able to work with the bank operations, credit risk and IT specialists to identify the cases concerned. We carried out the review of these cases and made recommendations to the client on specific redress requirements and approaches for each case which were then implemented by the client customer services teams.
A parallel phase of this work required us to recommend new arrears management policy, process and treatments to prevent similar problems recurring. This workstream worked with the internal compliance teams, operational contact centre teams, Credit Risk and senior management, as well as the FCA to agree the approaches we recommended. We then also developed policy and guidance for internal use and trained internal arrears handlers as well as those provided by a third-party outsourcer.