A. General remarks
1. Bank of Ireland is in favour of the publication of more comprehensive information relating to customer complaints on the F80 website and in the FSO's annual report. The he proposals advanced in the FSO's recent consultation paper are therefore generally welcomed by Bank of Ireland.
2. Bank of Ireland believes that the greater availability of information will serve several useful public purposes, cot least in encouraging financial providers to develop their internal complaint processes to ensure that these arc robust, and responsive, to legitimate grievances that customers have in relation to financial products and services.
3. The measure will also encourage companies to pursue all available internal avenues for complaint resolution, in preference to reliance on the referral of complaints to the Financial Services Ombudsman.
4. This said, there are several factors to be considered in the implementation of the broad proposal, factors which will influence the efficacy or the proposals. Some of these factors are raised in the consultation document (a proposed de minimis reporting, threshold, for example), while others arise or, detailed examination of the proposal.
5. As a general principle, while Bank of behold believes that mere comprehensive reporting is required, the benefits to be gained from such reporting must not be outweighed by disproportionate costs in the production and collation of complaint information or supporting information, such as market share information. It will also be important to have consistent classification of complaints across die industry.
6. Given the undoubted media and wider public interest there will be in the information being published, it will also be important that the information published is verified, in tandem with the relevant financial providers to which the information relates, before the publication of any company-specific complaint information.
B. Specific comments on questions
Do you think it is appropriate to publish details, for each financial services provider, as to: total number of complaints, complaints upheld, complaints upheld in part, total amount of compensation awarded? If not, why?
In the UK a cut-off of 30 complaints is used (i.e. information is not published if the financial services provider had less than 30 complaints and/or less than 30 complaints in a specific category). What level of de minimis number of complaints would you propose as being appropriate in Ireland and why?
By way of example the F50 has suggested that the de minim is threshold could be set at a minimum number of findings upheld/partly upheld. Do you think the de minimis threshold should apply to the number of findings upheld/partly upheld or should it apply to the total number of complaints by financial services provider including those not upheld? If you think it should apply to the number of findings upheld/partly upheld only please give reasons why.
Should the FSO include details of each financial services provider's market share? If yes, can you please give details of how you would suggest the market share figure should be calculated and/or from where it could/should be sourced.
Similar to the PSO case studies currently the FOS in the UK does not appear to disclose the names of either the customer or the financial services provider in the case studies it publishes. The FS0 is now considering whether the name of the financial services provider should be disclosed in circumstances where there is a compelling public interest to do so. Would you agree with the FSO proposal to disclose the names of financial services providers where there is a compelling public interest to do so? If not, why?
While the FRO is proposing to publish the information by financial services provider it hasn’t proposed to change the format in which information is published. The FSO currently publishes information across three general categories (Investment, Banking and Insurance) and within each general category the information is broken down by product type. Do you think the information could be provided in a more meaningful way? If yes, please provide details.