The Role Systems Have in Ensuring Compliance

Richard Carter

Chief Executive

Nostrum Group

Contents

• Context

• Where technology can help

• Diversification

• What now?

FCA Objectives

“…make markets work well.”

“...firms to put customers at the heart of their business.”

FCA Powers

“...robust approach to tackling problems...”

“...robust action...”

Technology – the loan

Origination

•Affordability

•Identity

•Loan documentation

Technology – the loan

Servicing

•Record everything

•Move to self service

•Service standardisation

Technology – the loan

Collections

•Flexibility and data analysis

•Self service

•Detailed notes

•Case segmentation

Technology – Reporting

• Invest in strong analytic capability

• Refine underwriting – risk based pricing

• Review CPA policy and timing

• Reporting back to FCA

Conduct

• Train staff and keep records

• Segregation of duties

• Accessible internal policies

• Appraisal and audit

• Define and follow the complaint process

Complaints

• Monitor social media and consumer forums

• Update the system with outcomes

• Evidence root cause review

• Fair redress and compensation

Diversification

Inside the definition

•Instalment loan with customer

friendly early termination• single assessment• more affordable• lower monthly payment aids CPA

•Change payment approach

Diversification

Outside the definition

•Guarantor loan

•Asset backed loan

•Innovate

What Now?

• Respond to the FCA consultation – 3rd December

• Work with your trade association

• Prepare

Richard Carter

Chief Executive

@NostrumGroup

www.nostrumgroup.com