The 5-minute Compliance Health Check

Use this tool to perform a quick health check of your collections operation and identify potential gaps before they become significant risks.  The health check is for guidance purposes only and does not constitute formal regulatory advice.

Section 1: Identification and Recording

Effective support starts with accurate and consistent identification. Your systems and processes must be equipped to spot, record, and share information about customer vulnerability.

1. Do we have a clearly documented, firm-wide policy for defining and identifying a vulnerable customer?

2. Do we train collections staff on how to identify not just obvious vulnerability but also potential, non-obvious signs?

3. Does our collections system allow an agent to easily and permanently flag a customer's account with a vulnerability marker?

4. Once a vulnerability flag is applied, is it instantly visible to all other agents and users who may interact with that customer in the future, across all channels?

5. Do our digital channels (e.g., self-service portals) provide a discreet way for customers to self-disclose their circumstances?

Section 2: Fair and Flexible Treatment

Once a vulnerable customer is identified, your firm must have the flexibility to offer appropriate forbearance and tailored solutions, moving beyond a one-size-fits-all collections strategy.

6. Can our collections system support a wide range of forbearance options beyond a standard payment plan (e.g., temporary payment holds, interest freezes, token payment plans)?

7. Do our agent workflows systematically guide them towards compliant, pre-approved forbearance options once a customer is flagged as vulnerable?

8. Do we have a clear and consistent process for signposting customers to free, impartial debt advice (e.g., StepChange, National Debtline), and can we track when this has been done?

9. Have our agent incentive and bonus structures been reviewed to ensure they do not create a conflict with the fair treatment of vulnerable customers (e.g., rewarding only cash collected)?

10. Are there clear, system-enforced procedures for handling customers who are in a statutory "Breathing Space" period?

Section 3: Audit, Oversight & Control

Demonstrating compliance requires more than just saying you do the right thing; you must be able to prove it with a complete, immutable audit trail for every single customer.

11. Can we, on demand, produce a complete and unchangeable audit trail for any given customer, detailing every action and communication?

12. Are all customer communications (call notes, emails, SMS, portal messages, letters) stored in a single, unified customer view, rather than fragmented across different systems?

13. Do we conduct regular reviews and analysis of customer outcomes (e.g., comparing outcomes for vulnerable vs. non-vulnerable customers) to ensure our policies are effective?

14. Does our system allow for robust access controls, ensuring that sensitive customer data can only be viewed by authorised personnel?

15. Can our compliance or management team easily monitor agent activity and customer interactions without having to manually pull data from multiple spreadsheets?

Please answer all questions before proceeding.

 

The traditional approach to managing debt – waiting for a missed payment – is no longer sufficient. It's time to shift from reactive firefighting to proactive support, fostering stronger bonds and protecting both your customers and your bottom line.

Flexys Pre-arrears Strategy guide
This checklist is for guidance purposes only and does not constitute formal regulatory advice.