Complaints are part and parcel of the advising process. If you are an adviser for long enough, you will certainly receive a complaint about some aspect of your advice. It might be something as simple as a client complaining that the value of their investment fell, which can usually be easily addressed. Or it might be that you have made an innocent mistake, which again can usually be easily addressed. Or it might be something of more substance that you need to consider in more detail.
Dover’s Approach to Complaints
Dover takes a pragmatic approach to complaints. They happen, and sometimes they happen for legitimate reasons. Dover is always happy to assist our advisers to deal with complaints. All we ask is that you are open and honest with us at all times about the complaint and everything connected to it.
Our experience is also that clients are quite accepting of adviser’s efforts to address genuine grievances. So, our advice is to tell the truth at all times and to work co-operatively with a complainant wherever possible.
In 2009, the Commonwealth Ombudsman published the Better Practice Guide for Complaint Handling. This guide, intended especially for government bodies, is also useful for any organization that provides services to the public. Financial advisers are certainly part of this group.
The Ombudsman’s report contains five elements. The fourth of these, commencing on page 21, is the most useful for our purposes here. We recommend that readers download and read the materials for themselves, but we offer below a précis for the materials and how they can be implemented in a financial planning practice.
The following diagram, prepared by the ombudsman, details the recommended process:
Step 1. Acknowledge the complaint
The first thing that should be done is that the complaint be acknowledged. Do this quickly, and Dover recommends that this be done in writing. An email to the complainant is an easy way to do this. Here is an example of how a complaint might be acknowledged:
It was good to talk to you today. I just wanted to create a written record of our conversation. You wanted to discuss your dissatisfaction with the performance of the investments recommended in my statement of advice to you dated 1 February 201X.
Please let me know if this is not correct.
I will be looking into the issue we discussed and will be in touch shortly.
Make sure that you save this email in the client file, as well as any response to it. If the client responds either by phone or by email to correct your understanding, send another email with the corrected understanding.
The point is to create a document that shows not only that you addressed the complaint but which also defines the nature of the complaint. The concept here is the same as the one employed when we work to establish client goals at the commencement of the advising process. By writing these goals down and having the client verify them (usually by signing the fact finder), you define all the work that follows. It is the same with complaints.
For Dover Advisers: you need also to tell us here at Dover whenever you receive a complaint. A copy of the client email, as well as your proposed response, should be sent to email@example.com.
Step 2. Assess the complaint
The next step is to assess the complaint. When assessing the complaint, we encourage you to do everything that you can to look at the issue from the client’s perspective. Doing this not only lets you better understand the complaint, but it also starts to tell you how you can best respond to the complaint.
For example, if you put yourself in the shoes of a client who is complaining about the value of an investment falling, then you will realize that this client did not understand the risk of his or her investment. The complaint is really an issue of client education and the remaining elements of the process can be adapted accordingly.
A big part of the assessment concerns how urgent the complaint is. To state the obvious, more urgent complaints need to be addressed as soon as possible. This leads to step 3.
Step 3. Plan the investigation
This is an important step. Responding to a complaint will not generate revenue for your practice – but an effective response will definitely save you time and money. Make responding to complaints a priority.
What the plan entails will vary according to the nature of the complaint. You may need to gather more information, contact various people, appoint a member of the staff team on the issue, etc. Your plan should also address how urgent the complaint is and whether there are any deadlines that need to be met.
Step 4. Investigate the complaint
In this step, you start to consider whether the complaint is a valid one. Has the client got a genuine grievance?
We can’t stress enough how important it is to be objective here. To be objective you must look at the issue from all sides, not just your own. Examine all aspects of the client relationship. Think about whether you followed your own protocols. For example, did you provide a Financial Services Guide to the client? Was your time with the client rushed in any way? Are there other factors that may have had an impact, such as the client having English as a second language such that they did not understand something that was said or written? If it was a member of your staff who did the work, are you sure that they followed all the right protocols.
Be prepared to accept that you made a mistake, if that is what happened.
At the end of this step, you should be able to tell whether the complaint is a valid one, and your response should be becoming clear.
Step 5. Respond
The next step is to respond to the complaint. The way you respond will vary according to what your investigation revealed. Returning to the example above, in the case where a client complains because an investment fell in value, you might need to return to those parts of the process where you discussed the risk of the proposed investment and explain these elements again. This actually allows you to turn the complaint process into a client education one.
When responding, always tell the truth. As Mark Twain said, people who tell the truth don’t have to remember anything. It is also the simplest way to address the complaint. In most cases, much of the confronting nature of a dispute is avoided if the adviser admits to a mistake: clients find it hard to stay angry with someone who accepts responsibility.
That said, if the complaint is not a fair one, don’t simply accept it. The customer is not always right.
If the situation can be rectified, do so. This might simply be to provide information to the client. If a mistake has been made, it will certainly be to rectify the error. For example, if a client has been overcharged, return the extra payment.
Typically, complaints should be responded to verbally in the first instance. The best way is with a face to face meeting, but if this is not possible then a phone call will do.
Once you have done this, once again harness the beauty of email and document the whole process – from the complaint, through your investigation and then your response. Once again, here is an example:
It was great to have the chance to meet with you yesterday and discuss the issues you raised with us last week. As we discussed, the fact that your investment has gone down in value is due to the inherent risk of a share-based investment. Over the long-term, we expect the investment to experience positive returns. But from time to time the value of the investment will fall.
In our meeting it seemed to me that you accepted that your experience is line with normal investment experiences. If that is the case, can I get you to acknowledge this by return email.
I look forward to seeing you again for a review on ___/___/___.
Again, save this email in the client file, along with any acknowledgement that your client provides.
Once again, for Dover Advisers: you need to tell us here at Dover how you have acted to respond to a complaint. A copy of the client email, as well as a description of your response, should be sent to firstname.lastname@example.org.
Step 6. Follow up
Once a complaint has been addressed, it is often a good idea to contact the client after a few weeks to see how they are going and to ensure that they no longer have a grievance. This is especially the case if you do not receive an acknowledgement of your response to the complaint. Hopefully, your response and follow up will have helped you retain a wanted client.
There may be times when the nature of a complaint and how it has been handled means that you wish to end the client relationship. This can be fair: who wants to work with someone who has been abusive or aggressive?
We recommend that any moves by the adviser to terminate the client relationship wait until the complaint is resolved. Acting before this happens can antagonize the situation further, and the complaint therefore becomes harder to deal with.
Step 7. Documenting and reporting
As discussed above, as soon as an adviser receives a complaint, they should report that to email@example.com. Dover should then be informed at each step of the complaint handling process.
Advisers must also record the complaint and the way it is handled in their complaints register, which is currently contained in a spreadsheet sent to each Dover adviser. (In time, this register will move to the adviser portal and will be completed online).
Here is an example of the register being completed:
Obviously, this register can then be cross-referenced to the appropriate client file.
Step 8. Think about your system
Sometimes, a complaint will make a systemic problem apparent. It may be, for example, that there is a step in the client communication process that is being missed, and that clients are then not expecting the outcome that they receive. Whenever a complaint is received, it is worth considering whether there might be other clients affected by the same issue.
Way back in the early 1990s, it was a truism in marketing that for every client who told you they were unhappy, there were 19 others who were unhappy but did not tell you. The idea was to encourage businesses to approach complaints from the viewpoint of client retention. This means that complaints are seen as an opportunity for genuine feedback, which is hard to get sometimes.
There is a lot of good sense in this argument. Often, clients leave a practice and they are too shy, too polite or too annoyed to tell you why they are doing so. If you are experiencing client losses and a complaint arrives at the same time, it can make sense to consider whether the complaint might indicate why the client have been leaving.
This can be especially the case if the complaint is to do with things such as personal style. For example, a complaint that an adviser did not listen might be one that other people notice but simply see as a reason not to continue.