DISP – 1.6 - everything that covers Final Response Letters and eight week letters

They say a change is as good as a rest don’t they, but wouldn’t it be refreshing if we could take a hefty swipe at DISP to tidy it up and get it updated for 2020 and beyond. So, this week’s DISP under the microscope is all about translating DISP 1.6 – covering everything to do with Final Response Letters and eight week letters. We’ll give you some food for thought, in terms of working within the framework of the rules that still loom large in today’s complaint handling.

Interestingly though, let’s start with 1.6.1 – keeping the customer informed, because a lot has changed since this rule was written and I think it bears a deeper examination through the lens of 2020, because it says:

  • Send the customer a ‘prompt written acknowledgement’, letting them know you have the complaint and you’re dealing with it; and
  • Keep the customer ‘informed’ of the progress of the complaint and the ‘measures being taken’ for its resolution.

More often than not the ‘written’ acknowledgement will be by email, rather than snail-mail, as would’ve been the case when this rule was written. But what do you say in the acknowledgement? Do you use a standardised ‘holding letter’ or do you take the time to personalise the acknowledgement from the off? It’s a tough one to balance if you are a larger company dealing with potentially hundreds of complaints in a day, but if you take the time to at say a bit about the complaint and a bit about what you’re going to be doing for them, it sets the tone for the complaint.

Imagine it, you’re seething that a mistake has been made and you’ve taken the time to contact the business to make a complaint (because it is an effort to do this…). This could be by telephone, where you’ve spoken to someone that empathises with what’s happened or not happened. They’ve listened to the complaint and then you get a rather naff looking ‘written’ acknowledgement that sounds like a robot and doesn’t tell you much of anything. How’s your confidence in the service you’re receiving? Not great I imagine.

But, if you, as a business, take the time to show that you’ve listened, and you’ve taken on board what the complaint is about, but that you’re also being open about what you’re intending to do about it. Wow! That speaks volumes about how serious you are about it and that you want that customer to have their complaint sorted in a very personal way.

Let’s move on to 1.6.2 – the very meat and bones of 1.6, because it’s all about the Final Response Letter, or the letter you send to tell the customer that you’ve run out of time, the rather inaccurately titled ‘written response’, that doesn’t include your response…(we’ll call it the 8 week letter)  

We all know what needs to be included in these two documents, at the very least for it to be considered a Final Response Letter of a ‘written response’:

  • A copy of the FOS’ leaflet
  • Provides the website address of the FOS
  • FOS referral rights to set the six month clock ticking
  • Whether you intend to waive any time limits

The only real difference is that the Final Response Letter will include the outcome of your investigation, whereas the eight week letter tells the customer why you aren’t able to answer the complaint and when you expect to.

But, here’s the thing – we see it time and time again. Businesses that have put a lot of work into the investigation process and have tried hard to get to the right outcome, or haven’t quite got there in time, only for these two letters to let them down massively. And the thing that each of the letters has in common is 1) it doesn’t show the ‘working out’ sufficiently and it doesn’t ‘sound’ like the person that the customer has been dealing with.

Let’s just illustrate this with an example. Insurer A has received a complaint from Mr Logan. Mr Logan has spoken with Nic on the phone. Nic has made sure that he has kept Mr Logan in the loop throughout the process. He has informed him of what he needs to look at and why, he’s even gone so far to manage his expectations, by informing him that he won’t be awarded £1,000 for the fact his insurance claim has been declined. I know, Nic is pretty amazing at his job!

However, Nicholas then wrote to Mr Logan with his findings and this was where it went wrong. The tone of the letter and the language used didn’t sound like Nic at all. He quoted terms and conditions at Mr Logan, but didn’t explain what they meant and why they applied. And he told him that Insurer A was unable to uphold the complaint, as ‘he had been unable to establish any wrongdoing on its part’. Now would Nic speak to Mr Logan on the phone like this? Seems very unlikely, and for that reason Mr Logan felt let down, as though Nic had disappeared and been replaced by a mysterious and officious Nicholas.

The same goes for the 8 week letter, because it could be that Nic was unable to answer the complaint within the timeframe and so needed to let Mr Logan know. But the letter was a missed opportunity to keep Mr Logan invested in the complaint with the business, because again, it was the unknown entity called Nicholas.

To be clear here, we’re not advocating not including the referral rights and not making the customer aware of the FOS, but this letter represents an opportunity to tell the customer what you’ve done so far and what remains outstanding – rather than just sending a letter that tells them you’ve run out of time. And let’s not forget that in 2020, eight weeks is a flipping long time to be waiting for the answer to a complaint.

Which brings us on to 1.6.7 – speed and quality of response. It’s the same old issue that has plagued complaints since the DISP rules came into being – how much time is the right time to spend on a complaint? You’d be forgiven for thinking it just needs to be sorted as soon as possible, but we know that this isn’t the case. People have a lot more communication channels through which to make a complaint, but that doesn’t mean they want an answer yesterday. It still remains the case, that too quick and you’ve not considered it sufficiently, but spending eight weeks on the complaint in 2020 is just too long. We’ve seen research from Huntswood, that suggests the optimum time is two weeks, worth bearing in mind if you’ve looking to reduce referrals to the FOS, especially as businesses covered by the Payment Services Directive are already aiming at this sort of turnaround time anyway.  

By looking at DISP and asking yourself some searching questions with today’s expectations and tech layered on, you can make DISP distant but also work for you, not the other way around…

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