How Outcomes Management can Strengthen Regulations for Inclusive Finance

Question 2: What method do you use to collect information, and where do you stand in the process? Who collects the information, and how do you obtain customer data?

We receive information from various returns, which are submitted to us by the regulated entities.  In the past some of these returns were similar to compliance reports, which required entities to confirm their adherence to regulations.  However, we realised this approach was too rule-based and functioned more like a tick-box exercise.

We changed our approach when we started thinking about collecting market conduct data. The returns had to give more insight into customer experiences and the outcomes being achieved in the industry.  We therefore started developing a specific market conduct return, with only quantitative questions, and subsequently rolled it out to the insurance sector as a first phase.  The data was submitted on a quarterly basis.

Currently, we are also receiving data on customer experiences, their perceptions of financial products and whether fair outcomes are being achieved from external customer sources.  We are in the process of further developing the market conduct return.  The new market conduct return will be cross-sectoral and supplement the external data which we already receive.

The approach remains the same: to communicate clearly with industry on what we expect and why we need the information.  Consultation and collaboration are imperative to the success of such a project.  The new return will be implemented by using a phased in approach.

Question 3: What are the main challenges you face in this process?

The first challenge is securing industry buy-in. While entities already have the necessary data, they may not have it in the required format or level of detail. Larger entities typically have the data but need to adapt their systems, while smaller FSPs may lack the necessary technology or awareness of the data’s benefits.

We must clearly communicate why we need the data, how we will use it, and what entities can gain from it. This process can be costly for both regulators and industry players. To address this, we are investing in new systems and collaborating with other regulators to avoid redundant information requests.

The second challenge is data quality. Even after seven years of implementation in the insurance sector, we still face issues with data completeness and accuracy. Initially, we allowed a three-year grace period where entities could submit their best efforts to help them adapt. However, improving data quality remains a long-term effort.

Another challenge is capacity—both on the industry side and within the regulator. On our side, we need skilled analysts who can interpret data effectively and facilitate meaningful discussions with entities. Building trust is also crucial, as entities need to believe in the fairness and purpose of the process.

Overall, it’s a long journey requiring continuous improvement in risk management and data utilisation.

Question 4: What advice would you give to regulators and financial service providers who are starting this journey?

I hope we are inspiring others, because there is a lot of value in this process for everyone.

One key lesson from our insurance industry experience is the importance of clear, transparent, and collaborative communication with the industry, from the start.

With the Omni-CBR, before requesting feedback, we conducted webinars for different sectors, explaining each question and its purpose. This built trust and ensured that entities understood our goals. Many entities then proactively engaged with us to clarify questions before submitting formal comments.

Despite this, we still received pushback, which is understandable and expected. This is a costly initiative, and regulators must be patient, allowing for multiple rounds of consultation and phased-in implementation. However, clear deadlines are necessary to maintain progress.

Industry players should avoid outright resistance. Instead of rejecting changes due to cost or complexity, they should actively participate in shaping the process. Regulators and industry are partners—this effort benefits both sides. Industry is always ahead of regulators in innovation, so collaborating helps regulators keep pace.

A key benefit of this process is creating a level playing field and improving consumer trust in financial services. Consumers need to see that real work is being done to ensure fair outcomes.

Question 5: If you had to choose one key indicator or type of data that you find most useful, what would it be?

That’s a tough question because I like many indicators!

One important aspect is that complaints data alone is not enough. While we collect complaints and customer survey data, we also focus on indicators that reveal corporate culture.

For example, beyond just tracking complaints, we ask:

• How long does it take to resolve a complaint?
• What is the customer experience like for payments, refunds, or fund transfers?
• How quickly does an entity execute customer instructions?

These turnaround time metrics allow for benchmarking across the industry. Entities often ask, “If this isn’t acceptable, what is the industry standard?” With this data, we can provide accurate benchmarking insights.

This is crucial for industry self-assessment and improving customer experience. I could talk about this all day, but I’ll stay with turnaround time indicators as my top choice!