Our shadow shopping review assessed Code Subscribers’ compliance with clause 20.1 of the Code. This clause requires Code Subscribers to stop or cancel a direct debit facility linked to a customer’s transaction account promptly on request by that customer.
Seven out of ten subscribers surveyed provided incorrect or inadequate advice though their call centres on this issue. When we retested the sample four months’ later, we found a 10% improvement in practices. We made several recommendations, including that Code Subscribers:
We examined 109 Code Subscribers’ compliance with Part B of the Code, which requires them to refer to the Code in their terms and conditions for products and facilities to which the Code applies.
We reviewed how the Code was embedded in website-based documents, including terms and conditions, product disclosure statements and privacy statements. Just under a third of subscribers were fully compliant while a quarter used either the former Credit Union Code of Practice or a mixture of the current and former Code in their terms and conditions documents.
We recommended that subscribers review their websites and all terms and conditions-related documents and links to ensure the Code was incorporated in the relevant terms and conditions for products.
We reviewed 101 Code Subscribers’ websites to assess information available to customers on the Code, internal dispute resolution (IDR) and external dispute resolution (EDR). In each of these areas, “visibility” and “accessibility” are key requirements under the Code to ensure customers can raise complaints and disputes.
Results identified good and poor practices. 43% of websites did not meet basic standards regarding visibility and accessibility. Only 23% of websites had the necessary information visible and accessible for a customer to find within a reasonable time.
We made several recommendations, including that subscribers: