Reporting on key information gaps

[david.mann]

• Overview
• Build an advanced search
• Creating the Xport (not applicable to Essentials clients)
• Running the report
• Now what?
• Identify missing data
• Consider the segment the client belongs to
• Identify gaps in the onboarding process
• Is additional training required?

Overview

One of the cornerstones of compliance with Consumer Duty is evidencing the contents of your board report.  Managing a large amount of client information when you’re busy delivering the service is difficult and it’s easy to miss things.  In this article, we discuss some ideas for being able to run a single data extract to spot key gaps in your client data.

This extract is based on individual clients rather than non-individual entities such as companies and trusts, but a similar approach could be adopted for them as well.

Build an advanced search

We will build a simple advanced search which ensures this report only runs across individuals, as opposed to trusts, companies or partnerships.  Once we’ve built this report, we can set it as the base search for the Xport.  This means that the report output will always contain individuals only - every time you run it.

• Go to the quick search box and click on Advanced (ensuring you’ve got Clients selected):

• On most sites, if you scroll down the list of advanced searches, you will see one called “Individual entities only”.  This should be present on most sites, but no problem if it’s not, you can create one.

To create your own advanced search if you don’t have the “Individual entities only” search already: 

• Click New at the top of the Advanced Search menu.
• Click Add to add a new criteria
• In the Field or Group tab, leave Field Group as Entity and, in Field, select Key Details | Entity Type
• Leave Operation as Equal
• In Value, select “Individual”
• Click Add
• Back on the Search Criteria screen, click Save at the top right
• Enter a meaningful name - e.g. “Individual entities only”
• Add a description of your choosing - e.g. “Finds clients who are individuals”
• Set the Permission to “Share with my groups” to ensure members of your team can use the search.
• Click OK

Creating the Xport (not applicable to Essentials clients)

If you are an Essentials or Essentials+ client, this Xport is already available on your site labelled "Consumer Duty - Key information gaps".

This is a suggested report structure.  You may find it helpful to include other fields / data points in this report based on how you run your processes and manage your clients.  

Essentials+ clients and those of you who manage your own site can create their own version of this report.

• From your user dashboard / landing page, select the Admin (cog) option in the left hand menu and then Integrations > Xport
• Click Add Report in the top right corner.
• Add a Report Title of your choosing
• Leave the Report Type as Clients and click Next in the top right corner.
• Click the blue cog next to the Clients datasource
• In the Saved Search dropdown, select your saved search - i.e. “Individual entities only” & click Save.
• Click the Add Column button in the Columns panel

• You can now start adding your fields.  Set the fields as follows:
• Datasource - Clients
• Category - Key Details
• Field - Entity Id
• Once done, click the Save + add more link at the bottom.

• Repeat for the remainder of the fields:
• Key Details | Entity Name
• Key Details | Client Adviser
• Key Details | Category
• Key Details | Entity Status
• Key Details | Date of Birth
• Key Details | Regulatory Classification
• Key Details | Client Active Date
• Key Details | National Insurance Number
• Contact | Preferred Email
• Profile | Investment Risk Profile
• Key Details | Capacity for loss
• AnnualSuitabilityReview | Financial Knowledge
• Key Details | Ethical Investor
• Key Details | Religious Considerations
• Key Details | Is the client within the Proposition Target Market
• Key Details | Reason for Negative Target Market
• Key Details | Notes for Negative Target Market

• At the end, click Save in the top right corner.
• Now to set the right visibility for your Xport.  Click the magnifying glass in the Visible By column and:
• On an Essentials site, set it to Group Visibility and then select your group(s).
• On your own site, set it as you wish, ensuring everyone who needs to see / use the report has access to it.
• The final step is to set the right editability for the Xport.  Click the magnifying glass in the Editable By column and set it to be editable by either Private/Users (select your admin users, can be multiple) or Group visibility (this will allow anyone in your team to edit the fields in the report setup).

Running the report

1. Click the Admin (cog) icon in the left hand menu and select Integration > Xport.
2. Scroll down to find your vulnerable clients Xport.
3. Click the down arrow in the Action column and click Execute > CSV Report.  Acknowledge the popup message.
4. The report will then be generated.

These steps explain how to run an Xport manually but it can also be scheduled if you want to run it at regular intervals automatically.

Now what?

Here are some best practice tips to help you analyse what action you need to take: -

Identify missing data

This will just be a case of filtering the extract on columns which are blank.  Some fields should be filled in for every client as there’s no reason for them not to be populated.

However, fields such as investment risk profile may not be relevant if you are offering only mortgage and / or protection advice to a client.

 

Consider the segment the client belongs to

Assess whether the data you have recorded across your client bank is appropriate based on the segment / proposition the client has taken up.

A key question relating to Consumer Duty is ensuring that the question about whether the client represents the target market for their proposition is recorded.

If the answer to this question is now, check that there are valid reasons recorded why they are on a proposition they don’t fit the usual profile for.

If there are queries with any of these, then in this same report, you have the client’s adviser name recorded so you can easily follow up with them.

Identify gaps in the onboarding process

Many of these data points could have been recorded during the onboarding process.  

Are there any patterns of deficiencies in your data?  For example, do the majority of the gaps appear in client records which have been created by specific individual(s)?

Is additional training required?

If you manage your own Xplan site, consider if there is value in making specific fields mandatory - so that you can be sure the data is recorded at the right time.