50 Shades of Confusion…

 In Uncategorized

I am a great fan of RiskSA and an avid reader of all
their publications.  Great was my
surprise when they included a link to a very confused and one-sided piece of
writing in RiskSAWired (11th of Feb 2015) under the following headline:

“CPA: who is entitled to your call centre recordings?
Protection Act compels companies to provide customers with a copy of a written
contract and all its terms and conditions. Telesales, however, is another

In this article the assumption is made that a
consumer may not be entitled to a copy of their voice recording, which
represents the contract, as entered into by the policyholder and with the
telesales agent binding the product provider. 
Based on this misguided “fact” and using the example of a badly executed
sales call with inadequate disclosures, the writer warns consumers to be
suspicious of all telesales.  Not once
does the writer make any mention of the due process that should have been
followed by a responsible company/person performing an intermediary service or
binding function, which should clearly have been the case in this example of
selling an insurance policy

Fortunately, not all telesales are created equally,
nor are journalists and their investigative pieces. Unfortunately, this article
highlights the generalisation and misconception around telesales, especially in
the financial services sector. There are companies or individuals who will take
chances or cut corners to save costs or increase sales, whether it’s telesales
or brokers.  For precisely this reason,
the Financial Services Industry is regulated to ensure that all policyholders
are treated fairly and the FSB is very clear that it will not tolerate any
deviance from the expected standards and regulations… there is not even 1 Shade
of Confusion on this point!

Even in the most compliant and controlled environment,
one would be foolish to expect that there would never be disgruntled or unhappy
customers, this is applicable to telesales, brokers or in fact, to any
non-financial services environment. The benefit of concluding these sales via
the telephone, rather than face-to-face, is that the calls are voice-logged and
referenced to the customer and the particular policy sold.   We
find that 90% of enquiries or disputes can be easily resolved by making these
calls available to the customer which confirms what was presented and disclosed.

At CDA we are passionate about providing innovative
solutions to the Financial Services Industry, which includes various
Intermediary Services, Outsource Services and Binding functions. As a
registered FSP we are bound (although not handcuffed!) by the same regulations
and codes of conduct as all other FSPs. 
We know that if a sale is not compliant the repercussions could be
severe, from dismissal of a telesales agent to fines imposed by the FSB and crippling
reputational damage.

Whenever we communicate to any of our clients’ potential
or existing policyholders, there are various controls and processes in place to
ensure that we firstly, treat the customers fairly and secondly, represent our
clients in a way that ensures that we remain compliant within the realm of FAIS
and all other applicable regulations. 
Some of these controls include verification of sales calls by an
independent team; ongoing product training and sales coaching; quality
assurance checks performed by our clients, our Compliance Officers and Key

Telesales Agents are not the rogues of the industry,
who manipulate and bind customers with little else than “cable-ties”.  Regardless of the many “perfect” sales made
and valuable service provided every day in our industry, whether concluded by a
telesales agent or a broker, any instance of non-compliance will be
highlighted, investigated, written about and this is justified and necessary to
protect the industry and the customer. 
It is important to remember that thankfully, these sales are the
exception rather than the rule.

We have geared our business to function effectively
and optimally within the stringent regulatory environment in which we have
chosen to operate.  We’ve been audited by
the FSB; audited by our clients; we hold all the required guarantees and
insurance policies; stand on our heads, lift our skirts (no we don’t, just
keeping your attention!) and meet the very strenuous service levels as required
by our clients and their stringent, unyielding compliance departments.  Even in this apparent constricting
environment, we have concluded over 500,000 sales of simple insurance policies to
the middle to lower income-bracket consumer, who would traditionally not be
serviced by a traditional broker. 

Telesales as a distribution channel is a necessary
and viable solution to reaching previously uninsured consumers and providing
them with cost-effective and essential cover. 

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