Skilled Person Report to consider the treatment of customers in financial difficulties, considering Consumer Duty

The Skilled Person Report was to assess the extent that customer in forbearance and repossession discussions had been treated fairly and provided with all suitable options to assist them during their period of financial difficulty.

We reviewed the firm’s policies and procedures for putting clients into a forbearance situation and the nature of engagement with customers including the nature of communications and their approach to dealing with vulnerable customers. We then considered the steps taken by the firm prior to invoking repossession of property and whether customers were provided with every opportunity to agree on an approach that avoided repossession.

Once we had assessed policies and procedures, we reviewed a sample of clients who had been through forbearance and/or repossession taking into consideration their individual situation.

Our work ensured that the business review programme initiated by the firm was comprehensive in its inclusion of all types of customer (including vulnerable customers), the full range of potential detriment that a customer in financial distress might suffer (including distress), and the calculation of any redress due.