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Financial services organisations should prepare for DDO & IDR

October 5 is D-day for DDO (RG 274) and IDR (RG 271) changes. Here’s why a digital response to the new regulations is your FinServ organisation’s best bet.  

October might seem a while away but if your organisation wants to be fully compliant with the Design and Distribution Obligations (DDO, RG 274) and Internal Dispute Resolution (RG 271) regulations, it’s time to act now. And as Stuart Ward, Director Financial Services at Salesforce, and Anna Martin, Salesforce Reg Tech Lead at PwC, discussed in their recent webinar, it’s not all bad news. The new requirements present an opportunity for organisations to put the customer front and centre and reap the benefits of a digital response that will enhance collaboration, analytics and transparency between teams to improve customer outcomes.

Heads up: DDO (RG 247) and IDR (RG 271) are coming

The DDO will commence 5 October, 2021 and represents a pivotal shift in how financial products are distributed to retail consumers in the Australian market. 

ASIC Commissioner, Sean Hughes, says the purpose of DDO is to “reduce harms suffered by consumers, caused by past instances of mis-selling conduct and poor product value. They embed a consumer-centric approach to the product lifecycle and should assist industry to deliver better outcomes for consumers…” 

Central to the DDO is the creation of a target market determination (TMD) for each retail product and a process for identifying triggers that would suggest the TMD is no longer appropriate for a particular product.

IDR is also effective 5 October, 2021 and details the updated requirements for how financial services organisations manage consumer and small business complaints under their internal dispute resolution process. Changes to be introduced with IDR include:

  • Broadening the definition of complaints
  • Including Social as a complaints channel
  • Triage of complaints where financial stress is being encountered
  • Use of analytics to identify and resolve systemic issues and for IDR process performance
  • Exec accountability for IDR effectiveness.

Onus or opportunity? How the new regulations can transform your business

Stuart Ward sees meeting the demands of these new regulations not simply as a compliance response, but as an opportunity to put the customer firmly at the centre of an organisation’s operations. 

“At the heart of these regulations is an increased focus on the consumer and meeting their needs. Information is shared between issuers and distributors to make sure products are the right fit,” says Stuart. “The onus is no longer on the customer to figure out what’s right for them. And simple disclosure doesn’t cut it anymore.” 

By engaging properly with the TMD framework, firms can start to build more trust with their customers. Offering relevant and meaningful advice about products appropriate to their needs can help consumers see the organisation as a valued advisor and one they are happy to return to. 

Reassuring consumers they could benefit from such advice will take time and a strategic approach.

“Think about it,” says Stuart. “More than ever, customers want to do everything on their own including research and decision making about what financial product is right for them. Firms need to find a way to engage them on that journey.” 

Enter ‘functional friction’ – a way of getting consumers to stop and think that perhaps it’s time to talk to an advisor. 

“Functional friction acts as a kind of guard rail to lead consumers in the right direction. Selecting an ill-fitting product should be hard. If a consumer is choosing a product but doesn’t fit the relevant TMD for that product, they could, for example, be referred to an advisor.” 

Yes, this is part of placing new onus on issuers and distributors to work within the TMD framework, but it also presents a valuable opportunity to develop relationships and drive a customer-centric experience.

Why a digital response to the new regulations is your best bet

Meeting the demands of DDO and IDR will be no small feat. The right digital platform will help organisations manage the data and the alignment that’s needed to get compliance right. 

Moreover, a platform response will help organisations drive that all-important customer centric focus. 

Technology enables automation of the TMD Lifecycle and the triggers associated with monitoring it. For example, a digital platform can, at a glance, share critical information about why a customer might be cancelling a certain product or through identifying patterns in complaints data. These findings can be linked to colleagues across groups to quickly identify any issues, adjust TMD’s if needed, then to notify distributors of the change. 

“There are huge potential benefits for marketing departments,” points out Anna Martin. 

Drilling deep into the customer demographics and segmenting data means marketers can optimise their spending by dealing with customers in the right TMD. 

Managing complaints in a way that’s compliant with IDR will also benefit from a data-rich, automated approach. The timeline of a response can be streamlined and the customer journey personalised appropriately over that period.

“What if a customer has made a complaint but while they are waiting for a response they keep receiving sales offers?” says Anna by way of example. An automated trigger that turns off those communications while a complaint is being handled is less vulnerable to the kind of human error that can end up escalating a problem. 

Moreover, it tightens up the timeline for complaint management, ensuring that products don’t stay off the shelf for long and organisations don’t go into breach over a complaint. 

“Technology can enable a collaborative response and connectivity between departments and between issuers and distributors,” says Anna. “Ultimately that uplifts the way we do things at every point in the customer journey and drives better customer outcomes.”

Think you’ve got it covered? Be very sure

In a recent speech, ASIC’s Acting Chair Karen Chester, “The easiest way to stay off our radar is by living up to Parliament’s and community expectations and following the DDO roadmap.”

October 5 is a hard deadline so organisations need to give themselves plenty of opportunity to be clear on the regulations and sufficient time to test their platforms for compliance. 

“If you think you’re good to go because you’ve got systems in place based on the previous regulations, you need to think again,” says Anna. “The changes are significant, and a robust system to deal with them is not a nice to have – it’s critical.”

Anna also points out that a change management strategy will be essential to getting any new platform right. 

“Often the assumption is that everyone in the organisation will be comfortable with change in the same way. That’s rarely the case. Some people will need intensive support and meeting your compliance obligations will depend on your organisation delivering that support. If you have agents who don’t properly understand the systems, you could end up with cases coming close to breach or agents missing something crucial that leads to an unfair customer outcome.” 

Ultimately, compliance with DDO and IDR gives your business the opportunity to transform into a truly customer-focused organisation. Act now to ensure you get there by 5 October 2021.

For more insights from Stuart and Anna on how to prepare for DDO and IDR, watch the webinar

Hear about the latest developments and trends within the financial services sector from the Salesforce Live: A&NZ – Financial Services Day. Watch all the on-demand sessions here.

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Stuart Ward

Stuart Ward is responsible for APAC financial services strategy at Salesforce. Covering Banking, Insurance, wealth and capital markets, Stuart draws more than 15 years experience in global finance, addressing evolving opportunities and challenges facing the industry. Prior to joining Salesforce, Stuart worked for ANZ Bank, where he established the institutional bank’s business analytics capability. He was instrumental in bringing together technologists and business teams to deliver transparency, enabling better decision making across the business. Stuart's career includes consulting, marketing and production management of dealing rooms within JPMorgan and Citi. Working closely with trading risk and operations is where Stuart developed a keen passion for finance. Stuart holds a bachelors degree in Information Science and a masters degree in Applied Finance.

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