(London):  Fair treatment of vulnerable customers has been high on banks’ agendas since the Financial Conduct Authority (FCA) issued guidance in 2015. In the three years since, financial institutions have invested time, money, and effort to identify and improve outcomes for customers in vulnerable situations.

Vulnerable consumers, or those whose personal circumstances make them especially susceptible to detriment, make up 2.4% of credit card accounts and 3% of balances, on average, according to Auriemma’s UK Card Collections and Recoveries Benchmark. However, the size of vulnerable populations varies widely based on portfolio composition and other factors, with some issuers reporting larger populations.

Until recently, vulnerability was tied to debt collection, as there is a natural correlation between vulnerable customers and those in arrears. Now, attention has shifted to proactively identify vulnerable consumers across the product lifecycle, with more precise treatment applied based on customers’ personal circumstances.

“Vulnerability is an increasingly complex concept and cannot be treated as a binary phenomenon,” said Louis Stevens, Director of Auriemma’s UK Roundtables practice. “While card issuers recognize the benefit of having a standardised definition for vulnerability across the industry, it’s virtually impossible to capture all the grey areas with a single, uniform classification system.”

Here are three ways financial institutions are taking a more targeted and holistic approach to address customer vulnerability:

Proactively identifying vulnerable customers. While customers in arrears tend to be more vulnerable, issuers are embedding their approach across more functions of the organisation. Over the past year, the focus has shifted toward identifying potential vulnerability, regardless of where the customer is located within the lifecycle. For example, Customer Service teams are now tasked with identifying triggers or clues to vulnerability, such as a mention of illness, and proactively monitoring potentially vulnerable customers even if they make payments on time.

“By definition, vulnerable customers are anyone who can suffer difficulty, and it’s the job of financial institutions to identify and rehabilitate that,” Stevens said.

Tailoring treatment to individuals. While the FCA defines vulnerability broadly, financial institutions have developed more precise definitions to meet non-standard needs across a diverse customer base. Most card issuers use two broad categories to determine severity – for example, “soft” vs. “hard,” “temporary” vs. “permanent,” – with further sub-categories to capture the nuances of a customer’s situation. In fact, issuers may have 20 or more classes of vulnerability to ensure a flexible, tailored response. For example, a customer with hearing or visual impairment may need special assistance to complete routine payments. These cases may not typically be indicative of financial difficulty but can be a sign of vulnerability.

Maintaining a flexible exit strategy. Effectively dealing with short-term vulnerability, such as temporary unemployment, is another key consideration for financial institutions. In particular, it’s important to have a defined exit process for customers who move out of a vulnerable situation, to ensure vulnerability treatment is accurately applied and customer care efforts are appropriately prioritised. Card issuers are taking steps to establish regular contact to monitor the customer’s situation and ensure timely removal of vulnerability flags for rehabilitated customers.

“Anyone can find themselves in vulnerable circumstances,” Stevens said. “Financial institutions will continue to reevaluate their vulnerability strategies to ensure a culture of empathy, support, and inclusion.”


About Auriemma Group

For more than 30 years, Auriemma’s mission has been to empower clients with authoritative data and actionable insights. Our team comprises recognised experts in four primary areas: operational effectiveness, consumer research, co-brand partnerships, and corporate finance. Our business intelligence and advisory services give clients access to the data, expertise and tools they need to navigate an increasingly complex environment and maximise their performance. Auriemma serves the consumer financial services ecosystem from our offices in London and New York City. For more information, call Louis Stevens at +44 (0) 207 629 0075.

(London, UK): Hold the phone: Email is cardholders’ most preferred means to communicate with their credit card providers, but concerns remain before issuers can deliver a consistent customer experience in that channel. Email topped the list of all channels, including phone calls manned by agents, live chat, mobile apps and SMS, according to Auriemma Group’s recent issue of UK Cardbeat.

Nearly four-in-ten cardholders prefer email when communicating with card issuers. Despite this consumer preference to communicate with card issuers by email (and with younger cardholders ages 18-34 also preferring live chat or mobile apps), issuers had not—until this year—invested as heavily into the channels for servicing or Collections-related activities. At a recent meeting of Auriemma’s Collections and Recoveries Roundtable in London, Collections executives discussed how digital channels could offer new opportunities to refresh contact strategies.

When weighing particular channel investments, issuers must analyse the performance of each potential channel and determine the contact methodology and channel mix that creates the best experience and increases an agent or collector’s success. Issuers are exploring how different channels can augment contact rates and payment rehabilitation within collections. For example, some executives are in the process of testing email’s efficacy by sending default notices digitally along with a conventional letter.

“The industry knows that email could be a highly successful contact channel, particularly for those in collections who tend to close off contact at some point in the lifecycle,” says Louis Stevens, Director of UK Industry Roundtables. “There is opportunity to develop email as a priority channel instead of a supplementary one. Many collections operations today are centered around a call-and-collect model, which could be less effective as cardholders skew toward preferring digital communication.”

However, integrating digital channels into the collections process can be a challenge, due to legacy system restrictions and painstaking approval processes. Currently, only 20% of Roundtable members offer live chat within the collections process, and further progress has been limited by the prioritisation of other controls, such as conversation transcript recording.

Despite the momentum for email, it is important that issuers maintain an excellent experience in the phone channel, which is the second-most preferred. One-third of customers prefer speaking with a representative on the phone, which is starkly higher than the 3% who prefer an automated service, such as an IVR.

Even though consumers have a strong preference for migrating more routine activities to digital channels, the phone is still the centerpiece for more in-depth and complicated interactions. This is evidenced in the Card Collections and Recoveries Roundtable Benchmark Study, which reports that the average handle time for calls has increased 11% since January 2018.

“Consumers don’t mind using self-service or automated options for simple tasks, such as due date inquiries,” says Stevens. “But for now, cardholders still call when they need a more impactful and in-depth experience.”

Survey Methodology

This study was conducted online within the UK by an independent field service provider on behalf of Auriemma in March-April 2018, among 800 adult credit cardholders. The number of interviews completed is sufficient to allow for statistical significance testing between sub-groups at the 95% confidence level ± 5%, unless otherwise noted. The purpose of the research was not disclosed nor did the respondents know the criteria for qualification.

About UK Card Collections and Recovery Roundtable 

Auriemma Group runs a series of information sharing and benchmarking Roundtable groups designed for executives and managers in collections and recovery. These Roundtables combine executive meetings, industry-leading operational benchmarking, and peer group surveys to help participants identify tools, technologies, and strategies to offer best-in-class customer experience at all touch points.

About Auriemma Group

For more than 30 years, Auriemma’s mission has been to empower clients with authoritative data and actionable insights. Our team comprises recognised experts in four primary areas: operational effectiveness, consumer research, co-brand partnerships, and corporate finance. Our business intelligence and advisory services give clients access to the data, expertise and tools they need to navigate an increasingly complex environment and maximise their performance. Auriemma serves the consumer financial services ecosystem from our offices in London and New York City. For more information, call +44 (0) 2076-290075.

(London, UK):  Since the European Parliament adopted a new standard to improve data protection for individuals within the European Union (EU) in April 2016, firms have faced massive fines for non-compliance. In the UK alone, the fines doubled year on year. Bring on May 2018 and a new set of standards set by the General Data Protection Regulation (GDPR) which aim to provide predictability and efficiency for organisations and offer all EU residents increased data protection rights.

The potential fines for non-compliance are unprecedented: Fines range between €10 million (£7.9 million) or 2 percent of an organisation’s global turnover (whichever is greater) up to €20 million or 4 percent of turnover (whichever is greater). For many businesses, fines could result in severe cash flow problems, insolvency or even bankruptcy/closure. The Information Commissioner’s Office (ICO) fines are currently capped at £500,000 which GDPR will override.

GDPR applies not only to EU domestic business, but to worldwide companies targeting goods and services to European citizens. Some of the key requirements include: increased rights for data subjects, the development of security-first software, encryption of personal data, secure data processing and a 72-hour notification for data breaches containing personal data. The UK Government have confirmed that Brexit will have no impact on the adoption of GDPR.

But many organisations are not yet ready, according to a recent poll one in three of all businesses in the UK are not familiar with GDPR. Many also believe that the regulation does not apply to their business. At Auriemma’s latest slate of Industry Roundtables, anxiety was expressed about the amount of work remaining to be ready by the deadline. Some of the most widely talked about components of GDPR compliance at the recent Auriemma events include:

  • Increased rights for data subjects (i.e., the right to “be forgotten” and data portability)
  • Software to be developed with security in mind (privacy by design and by default)
  • Pseudonymisation or encryption of personal data (privacy by design and by default)
  • Secure processing of data
  • 72-hour notification for breaches of personal data

To account for these changes, most organisations will have to fundamentally change the way they manage and protect data. A shift of this size will need buy-in from the board level and firms should be endeavouring to make sure all employees are aware of the requirements.

To help financial service firms best navigate the GDPR and PSD2 landscape, Auriemma will be holding a UK regulatory Roundtable in London on the 26th January.

We are fast approaching the end of two-year adoption period and 25th May 2018 is when the ICO expect all to be GDPR ready. Organisations should be adjusting their policies, internal and external procedures for data security breaches and considering the new rights of the EU citizens. It will be necessary for all to analyse its current privacy policies, security measures, and underlying operational processes. Firms will also need to identify areas for which process improvements and redesigns are required to ensure compliance with GDPR.

About Auriemma  Group

Auriemma is a boutique management consulting firm with specialized focus on the Payments and Lending space.  We deliver actionable solutions and insights that add value to our clients’ business activities across a broad set of industry topics and disciplines.  Founded in 1984, Auriemma has grown from a one-man shop to a nearly 50-person firm with offices in New York and London.  For more information, contact Louis Stevens at +44.(0) 207.629.0075.

(London): The FCA is conducting research on consumer repayment behaviour to alleviate persistent debt in anticipation of a new package of remedies. The additional research follows the Credit Card Market Study Final Findings released in July.

Everything from behavioural cues to statement presentation could potentially influence payment behaviour, an FCA representative said during a Q&A session at Auriemma’s Card Finance Roundtable in October. While at the meeting of card issuers, the regulator detailed some of the hypotheses it is testing, including how different consumer segments react to behavioural nudges around suggested repayment amounts, the impact of minimum payment “anchoring,” and how the presentation of amortisation can stimulate repayment habits.

Six months of data will be used in the analysis to assess the study’s impact on consumer behaviour and monitor for unintended consequences.

The FCA also detailed an additional study in collaboration with The UK Cards Association, focussed on further conceptualising early intervention and establishing a set of escalation tools firms will follow to encourage consumers out of persistent debt.

“The FCA has acknowledged that behavioural nudges may not work for all customers, as some may be in financial difficulty,” said Matt Bethell, Senior Associate of Auriemma’s UK Industry Roundtables. “The output of these additional studies will be remedies that incentivise firms to escalate intervention around persistent debt, without damaging customer service.”

The follow-up studies directly respond to some of the FCA’s more significant conclusions from the July study, including the identification of two consumer groups requiring attention:  those carrying debt for longer than three years (most likely due to habitual minimum payments) and those moving rapidly from acquisition to problem debt within one year. To identify these groups, the FCA requested significant data sets from issuers and ran analysis across the product lifecycle. The FCA compared the returns of credit card products for both low- and high-risk consumer segments and found that, between 2010 and 2014, returns were typically six percentage points greater on high-risk segment products. One quarter of accounts taken out in 2013 by consumers within the high-risk segment were in severe or serious arrears by 2014.

“While the FCA concluded that the market is working well for the majority of consumers, and that product cross-subsidisation was not materially impacting competition, it also believes firms have fewer incentives to address consumers with persistent levels of debt and should be intervening earlier,” Bethell said.

While the full implications of the results of these studies are not yet known, issuers are anticipating changes to their portfolio economics and, potentially, value propositions. These developments will be key agenda items at the Card Finance Roundtable in the year ahead.

About Auriemma Group

Auriemma is a boutique management consulting firm with specialised focus on the Payments and Lending space. We deliver actionable solutions and insights that add value to our clients’ business activities across a broad set of industry topics and disciplines. For more information, please contact Matt Bethell at +44 (0) 207 629 0075.

(London):  Supranational regulations such as the European Payment Services Directive 2 (PSD2) will burden credit card portfolio profitability and create new risks and opportunities, Auriemma Group said today.

The impact of PSD2 on credit cards and issuers more broadly was at the forefront of the agenda at Auriemma’s first UK Card Finance Roundtable meeting of 2016. The executive group, which convenes Finance Directors, CFOs, & SVPs of Finance and Accounting for leading issuers, meets regularly to discuss key financial management and compliance-related topics. The wide reaching implications of the directive ensures it features across all of Auriemma’s UK roundtables, from our UK Collections and Recoveries Roundtable to UK Customer Service, and is also a focus of discussion at our Fraud Operations Roundtable next month.

PSD2 is set to be one of the most disruptive payment directives ever implemented in the UK, when it is adopted by member states in 2018. While the first iteration of PSD in 2007 aimed to make payments simpler and more efficient across Europe through the creation of the Single Euro Payments Area (SEPA), the implications of PSD2 are far more potent for issuers and payment providers more broadly.

PSD2 will open the payments infrastructure and allow access to consumer account information to market players through the use of Application Programming Interface (API). By facilitating this direct access, API will establish two new roles in the EU payment landscape: Account Information Service Providers (AISPs) and Payment Initiation Service Providers (PISPs).

“Opening the payment landscape presents a unique set of challenges for issuers and card schemes, while presenting retailers and information aggregators such as comparison websites with previously inaccessible data,” said Carina Da Cruz, Director of UK Industry Roundtables at Auriemma.

Practically speaking, a PISP will have the right to initiate payments on behalf of the consumer by establishing a direct connection with the consumer’s bank upon authentication. Consumers will grant a PISP, such as an online retailer, permission to perform a payment transaction directly, thus bypassing multiple traditional payment participants including, most obviously, the merchant acquirer and card scheme. Significantly, this relationship will stay active to facilitate future payments until the consumer removes permission.

Second, AISPs will for the first time provide consumers with an aggregate view of their financial situation by combining multi-institution account information into a single portal. AISPs will have a direct connection with each financial institution and aggregate this information through a single authentication portal. More significantly, with this information AISPs will have the ability to cross-sell consumers more relevant, tailored propositions based on usage data.

The introduction of new players with direct access to consumer data will undoubtedly present significant challenges to issuers by way of lost revenue and increased competition. However, there are significant opportunities for issuers; members of Auriemma’s UK Card Collections and Recoveries Roundtable meeting in February discussed the challenges of obtaining reliable consumer financial information to complete accurate affordability assessments. API could allow issuers to assess debt affordability to a previously unattainable level of accuracy.

“API opens up a host of new opportunities to produce better customer outcomes, and issuers should rightfully be asking the European Commission for greater clarity regarding their ability to access cross institution account information to facilitate this,” said Da Cruz.

At the Auriemma UK Card Fraud Operations Roundtable in April, members will discuss the technical details of implementing new authentication processes mandated by PSD2. Opening the payment landscape to new players will require next generation multi-factor authentication technology to ensure consumers are protected and liability is shared fairly.

“PSD2 will remain front of mind for members across all of our UK roundtables as adoption looms,” said Da Cruz.  “Our model provides the ideal opportunity for market players to discuss the technical detail of the directive and assess the impact on individual portfolios.”

About Auriemma Group

Auriemma is a boutique management consulting firm with specialised focus on the Payments and Lending space. We deliver actionable solutions and insights that add value to our clients’ business activities across a broad set of industry topics and disciplines.  For more information, please contact Tom LaMagna at +44 (0) 207 629 0075.

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