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This industry update is more than 1 year old

Industry update

Dear CEO: Customer service standards

Customer Satisfaction

The Deposit-Taking Code of Practice Principles 2 and 3 state: ‘A registered person must have due regard for the interests of its customers’ and ‘A registered person must organise and control its affairs effectively for the proper performance of its business activities and be able to demonstrate the existence of adequate risk management systems.’ With this in mind, the Jersey Financial Services Commission (JFSC) is highlighting reports of a declining trend in customer satisfaction across the Banking sector, following the receipt of intelligence from various sources.

Themes of customer dissatisfaction that regularly come to the JFSC’s attention include, but are not limited, to the following subjects.

Client interactions

The main areas of customer service that cause dissatisfaction include:

  • transparency and clarity of communication;
  • timely response and execution of requests;
  • the ability to access someone live and knowledgeable when needed; and
  • accommodation of unique circumstances and vulnerability where reasonable to do so.

Power of Attorney

It is often a time of vulnerability and sensitivity when it has been necessary for a Power of Attorney (POA) to be appointed, and the POA needs the easiest means of carrying out banking activities for the person they represent. Many complaints are raised and escalated due to the POAs feeling that Banks do not work with customers to ensure that information and processes facilitate an awareness of, and support the proper use of POAs, on behalf of customers (both international and local) who have such a need (especially those who are vulnerable or in an aging demographic).

Fraud awareness and processes


Complaints on fraudulent activity of customers’ accounts cite a lack of a concerted effort by the Banks, to identify and inquire about unusual transactions before they are executed, more effectively addressing authorised push payment (APP) fraud, and more diligent action to recover funds transferred once a fraud is uncovered.

Banks’ Senior Management should ensure:

  • there is clear responsibility locally for the implementation of policies and procedures for countering the risk that bank’s operations in Jersey might be used for APP fraud and other payment fraud
  • that adequate measures are taken to address APP fraud and other payment services fraud.

The JFSC takes all types of fraud, including APP fraud, and the harm it causes to consumers, very seriously.

Complaint handling


Paragraph 3.6 of the Deposit-Taking Code of Practice states ‘A registered person must establish and maintain an effective customer complaint handling system and procedures.’ Intelligence points to instances of a lack of: commitment to effective internal complaint handling, active sharing of complaint themes, and root cause analysis to support continuous improvement throughout the business.

Failings on the parts of Banks call into question adherence of the Code in respect of:

  • 3.6.1.2 inform customers of how complaints may be made and how they may expect these to be responded to;
  • 3.6.1.3 handle customer complaints transparently, competently, diligently, and impartially;
  • 3.6.1.5 keep the complainant informed about the progress of their complaint, including details of any actions being taken to resolve their complaint;
  • 3.6.1.8 enable consideration of customer complaints data for patterns emerging.

Next steps


The JFSC requests that Banks consider the points raised above in respect of ensuring their compliance with Principles 2 and 3 of the Deposit Taking Business Code.

We hope to see more positive trends in customer satisfaction, fraud prevention, and complaint levels over the coming months. We will continue to consider the impact of these and will seek to take further action if we deem it is needed.

Banks can expect an increased focus on customer satisfaction and complaint handling in their meetings with Supervisors in 2023.

You do not need to notify us of any action in response to the points raised. However, we may want to discuss customer satisfaction in any future engagement with your organisation.

Should you wish to discuss further, please engage directly with your supervisor.