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Remediation activity is set to increase in 2021

Remediation has become a near-permanent activity for many financial institutions with product mis-selling, service failures, systems outages and degraded record keeping (e.g. KYC / CDD files) all creating demand.

KPMG believes levels of remediation could rise even further in 2021, fuelled in part by COVID-19:

  • Reviews of suitability and feasibility of products issued during the crisis may be required.
  • Collections and recoveries activity is likely to be necessary across COVID-19 funding areas such as mortgage holidays.
  • Remedial KYC / CDD requirements may be needed for new customers fast-tracked through onboarding to allow access to CBILs and BBLs.

We also expect to see a steady stream of service breakdowns requiring rectification. Key issues may include:

  • Weaknesses and blind spots in the increasing large number of digital journeys.
  • Processing errors arising from the increasing use of machine learning and AI.
  • Remediations required to respond to errors in manual workarounds.

Increased product-specific remediation may also be on the horizon in areas such as interest only mortgages, early redemption charges on advised sales of mortgages and credit card customers with persistent debt.

Many institutions will also need to process the tail of PPI cases at the same time.

Given these dynamics, the imperative to execute remediation accurately, quickly and cost-effectively will be more acute than ever. 

A holistic approach to remediation

KPMG can work with you across the remediation lifecycle: 

1. Prevention

We can deploy KPMG’s unique risk assessment and diagnostic tools to evaluate the effectiveness of your operations in mitigating Conduct and Financial Crime risks. We identify emerging issues and define effective approaches to resolving them, reducing the likelihood of financially costly and reputationally damaging downstream remediation. 

2. Delivery

Sometimes, remediation is unavoidable. KPMG has multiple delivery models and can define a remediation solution which is tailored to your needs: 

Outsourced solutions

Our Managed Services function provides comprehensive, outsourced remediation solutions. We can operate at the scale your remediation requires, with the ability to deploy large teams of 100+ FTE in an onshore/offshore and nearshore capacity. We can work by remote-accessing your technology or by taking your data into our own secure environment; increasingly, our use of leading-edge remediation technology and data analytics is enabling us to drive up case quality and productivity and reduce both cost and headcount requirement.

Our Managed Services engagements typically adopt the following high-level process:

  • We begin with an accelerated mobilisation period during which we leverage our deep experience in defining compliant and efficient remediation polices and in operationalising them using tried-and-tested processes, customer journeys and technology solutions.
  • Our team of experienced Remediation Analysts, Operations Managers and Subject Matter Experts then conduct the remediation, delivering accurate and consistent case outcomes which are achieved at high right-first-time rates. Our robust governance framework ensures that you are informed of our progress against KPIs through regular touchpoints and granular MI.
  • Finally, we work with you to migrate remediated files and data back into your in-house systems to ensure a smooth transition back into business-as-usual operations.

 

In-house delivery

If your preference is to conduct remediation activity in-house, we can provide a full range of services to help you design, build and deliver an effective remediation operation. Areas in which we typically help our clients include:

  • Enhancing the effectiveness of in-house remediation centres of excellence, focusing on delivering high quality regulatory and customer outcomes at optimal cost efficiency
  • Landing a ‘Day 1 team’ rapidly to mobilise an effective remediation operation, leveraging standardised and proven policies, processes, organisation designs and governance models.
  • Using data sourcing and analytics techniques to identify impacted customers and to determine appropriate treatment strategies.
  • Sourcing the data required to quantify remediation impacts and to build case files.
  • Conducting volumetric forecasting to define resource requirements and planning deployment to ensure optimal operational efficiency.
  • Designing, building and deploying effective remediation technology solutions such as redress calculators, workflows and AI-led automation of rules-based activities.
  • Augmenting remediation capacity by deploying experienced analysts, remediation managers and subject matter experts, using KPMG Flex 

Transformation

We go beyond remediation, working with our clients to identify the root cause issues which led to the need for remediation and to design and deliver sustainable enhancements to business-as-usual operations to reduce significantly the likelihood of the same / similar issues recurring.

We can also conduct assurance testing of post-remediation transformation activity you have conducted to assess its effectiveness in addressing root cause issues.

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