Under the regulatory framework ushered in by the Financial Conduct Authority (FCA), never before has it been so important for organisations to ensure that they have an effective and fair tracing system in place. It is no longer the case that a ‘one size fits all’ approach is appropriate when it comes to tracing activity; businesses need to ensure that appropriate treatments are applied to individual cases and that adequate provisions are in place to ensure that third parties are not contacted in error. In particular, there are likely to be significant repercussions for those organisations who repeatedly contact the same third parties in error, both from a compliance point of view and, more widely, in terms of damage to that organisation’s reputation. As Wescot is well aware, it is important to treat actual customers fairly. It is equally as important to try and avoid distress for third parties who may be approached by mistake.
One problem faced by businesses is over how to identify a genuine ‘goneaway’ situation. The new regulatory regime reflects this. The issue is also relevant when it comes to determining whether reasonable attempts have been made to make contact with a customer before any formal action is taken to recover the debt. It is no longer acceptable for an organisation to plough on regardless with formal action and ignore the fact that a customer has failed to respond to letters sent to him and that he has failed to answer telephone calls.
Also of relevance is the fact that the way organisations interact with customers has changed dramatically over the last few years. In many b2c relationships, the vast majority of contact is online. If it is a longstanding relationship which suddenly turns into a non-contact scenario, the challenge faced by a business is to consider whether the last known physical address and telephone details for that customer are correct. In this climate, many businesses are likely to benefit from effective early arrears reconnection services. Not only can this approach maximise the chances of recovery, it can also increase the chances of rehabilitating the relationship between the customer and the organisation. Businesses are likely to benefit from approaching a company with a proven track record in customer tracing. Wescot for instance, employs a highly experienced locate team coupled with an effective validation process – both of which combine to help re-establish contact between customer and client.