ASIC releases practical field guide on consumer-centred remediation programs

This phase entails an understanding of the problem itself and which consumers are potentially affected.

How to identify the issue at hand

• Work out the root cause, any underlying drivers and how to prevent it from happening in the future
• Draw on information and expertise from various business units within the organisation to fully understand and resolve the issue
• Consider whether it is more widespread than first expected
• Identify any common, underlying threads that led to the issue by analysing which products, services, systems, processes and people are involved and impacted
• Document the process to inform the cause of the issue, any knowledge gaps, and steps taken to resolve the issue

Assessing the population of affected consumers and extent of potential loss

• Cast the net wide
• Adopt an ‘if-not-why-not’ approach, i.e. what evidence is available to support the conclusion that a consumer is not potentially affected?
• Conduct testing to confirm whether all those affected have been captured

Working in tranches

To increase efficiency, licensees should aim to work in tranches once consumer cohorts have been determined, and prioritise consumer groups as appropriate.

Inadequate records

For a remediation to be consumer-centred, it is imperative for licensees to know their consumers, as well as their lives and needs. It is important to acknowledge that the issue being addressed in the remediation is in addition to everything else that the consumers are navigating in their lives.

This stage involves identifying any knowledge gaps and working out how those gaps may be filled.

A consumer-centred remediation journey involves minimal consumer action.

Factors to consider in the design of consumers’ journeys include:  

• Minimising complexity for consumers and making it easy for them (e.g. refunds should be processed automatically where possible)
• Being mindful of the wider impact on the consumer and putting things in the context of other life events and tasks that are ongoing in their lives
• Being ‘fault tolerant’ – consumers should not be disadvantaged if they made a mistake (e.g. forgotten to respond within specific timeframes)
• Do not make assumptions as to the way consumers would react or behave in this journey  

The plan should be formulated on the basis of the consumer journeys that have been mapped out and what is known about the affected consumers.

The following should be included in the plans:

• Timing and frequency of contact – at a minimum, contact should be made at the start and end of the remediation (unless in a very simple remediation)
• What messages and information would be communicated, when and from whom
• What communication channels would be used that are appropriate to consumers’ circumstances and fit for purpose – in most cases, multiple channels should be adopted to convey key messages in order to maximise consumer reach and response rate 
• Whether there are any calls to action (ideally none)
• What metrics to track and gather
• What testing is to be done on which pieces of communication and when
• Action plan for non-responsive consumers
• Central contact point for consumers to obtain additional support (e.g. translation services, financial counselling) and progress updates  

There is no one-size-fits-all approach in a consumer-centred remediation.

The content and appearance of the communications to consumers should be prepared with the following factors in mind: 

• The purpose of each piece of communication and whether it needs to be tailored to specific circumstances (e.g. literacy and numeracy ability, language skills and age)
• Keeping any requests for consumer action to a minimum
• Be transparent about what has happened, the timing of the remediation, the amount of the refund and how it was calculated
• Whether it is an appropriate stage to include information on how to lodge a complaint 
• Whether the contact details for access to additional support has been included
• Adopt simple language and short paragraphs; avoid legal jargon or unnecessary information
• Use behavioural insights where possible and appropriate but not in a way that suits business interests or applied as a ‘token gesture of consumer centricity’ 

What is a ‘soft launch’?

A process to test the effectiveness of the approach with a small, mixed group of consumers (not only one specific group) prior to a full rollout to all consumers.

What are the benefits?

• Helps refine the remediation, identify any issues and test knowledge gaps at the start
• Helps refine communications and internal procedures prior to the full launch
• Causes minimal delay (if any) to the remediation as a whole
• Helps save costs as the likelihood of having to revisit parts of the remediation is reduced

How to monitor outcomes appropriately

• Identify and track meaningful metrics to record progress against the outcome goal – ‘Consumer outcome’ is always a key metric to track in any remediation regardless of size
• Regularly record these metrics
• Conduct an analysis of the data obtained to identify and resolve any issues, and assess the outcomes against the goal
• Document the outcomes and any key learnings
• Revise and add new metrics as the process evolves