The scale of Gone Aways is immense reflecting some +10% of all customers at Life and Pensions companies and +5% of all customers in Asset Managers and Banks. Our evidence is that this number is increasing yearly. Our evidence is also that 15% of these Gone Aways are in fact deceased.
For the avoidance of doubt, our definition of a Gone Away is someone that an Institution knows is not at the address on file. Many in the industry do little to contact the Estate/Beneficiaries of those customers who are known to be deceased, simply awaiting reengagement initiated by their customers’ beneficiaries (which can only occur if the beneficiaries are aware about the policy/asset which in far too many instances is not the case).
Actions to Date and Why the Gone Away Problem is so Acute.
Some in the Industry who have started to address this issue have engaged with companies which provide Digital Linked Address Matching Services (or carry out Digital Linked Address Matching themselves).
This process involves comparing a file of their customers’ name and last known address information to that of available data from companies like credit reference agencies.
Digital Linked Address Matching is ineffective where databases are themselves not accurate, or, with an increasing population mobility, where people have moved out of the area or relocated overseas.
The Death register typically has the name of the hospital and last known address (which could be a Care Home) and the customer may have moved since taking out the policy/investment etc. Mortality screening uses Digital Linked Address Matching, so the lack of accuracy here should be of concern to those employing this service.
It is important to note that, whilst Digital Linked Address Matching may provide some frequency of results, the standard operating procedure is to provide the client with a ‘residency score’ or ‘gold, silver, bronze’ assurance levels. Many of these updates will in fact be erroneous and cause an institution to spend time and effort, with unnecessary cost, writing to invalid addresses. The true success of the Digital Linked Address Matching can only be ascertained following a reengagement process.
The weakness of Digital Linked Address Matching is evidenced by the number of Gone Aways left at an institution following the regular employment of these services.
Most in the Industry stop after this step suggesting ‘Nothing more can be done’.
At Vestigium, we are doing more as detailed below;
- Gone Away Solution
- Deceased Customer Solution
- Holistic Solution
1. Vestigium Gone Away Customer Solution
Vestigium has industrialised the process of forensic tracing for the purpose of asset reunification and/or re-engagement with Gone Away customers, specifically targeted to the Financial Services Industry. This reduces the scale of the issue, fast.
Vestigium’s methodology is to implement researcher guided forensic tracing querying combinations of in excess of 50 data sources on an individual basis to trace a known ‘Gone Away’ individual from their record-held address, to the address which they currently reside at.
Vestigium follows individuals through their address history and confirms at each stage. This is important as some individuals have been ‘Gone Away’ for years and their personal circumstances will have changed a number of times (this can include name changing as well as address changing or expatriation).
The current address is confirmed using recently renewed data sources such as electoral roll, telephone records, information on insurance products bought at the property, right through to open source intelligence and other methods.
When a Gone Away is found to be deceased, this is confirmed using DDRI, HALO, GRO, Probate records. Other genealogical methods may be used in the cases where the Gone Away has been deceased for some time.
Vestigium’s track record is to immediately find c.50% of a file not able to be found by Digital Linked Address Matching, with greater numbers over time. Of the 50% found immediately, Vestigium’s track record identifies c.30% are deceased.
Vestigium works to a targeted 99% accuracy for its results.
Vestigium classifies data into 3 categories; ‘found’, ‘pending’, and ‘never likely to be found’.
For those customers ‘found’, Vestigium provides the new details to its clients to enable them to re-engage.
‘Pending’ means that, in Vestigium’s view, the record held data is adequate for an eventual match, but the customer has yet to emerge into view on data sources to Vestigium’s confidence level of c.99% (an example of this is where a customer has recently moved and is yet to appear on data sources at the new address). Vestigium provides a Repository where these details will sit and are re-researched over time as data sources renew and become increasingly comprehensive, until a current address can be confirmed.
For the Industry this is Live-Archiving, where the Industry hasn’t given up but awaits consumers re-connecting. Vestigium believes this continual method helps institutions meet regulations including the FCA’s Principle 6, Treating Customers Fairly, and assists firms to meet the guidance set out on the fair treatment of vulnerable customers.
Vestigium will sign off ‘bad data’ as never likely to result in a match, so that clients can be confident in discontinuing spending resource on these records.
2. Vestigium Deceased Customers Solution
Vestigium is aiding its clients by tracing the next-of-kin, or Executors, of deceased customers to a current address.
Where customers of institutions have left probate, Vestigium will purchase the Will from the government, and trace the named Executor to their current address using the methods outlined above.
Vestigium provides its clients with both the current contact information for the Executor, and a copy of the Will/Probate documentation.
For those customers who haven’t left Probate, Vestigium employs genealogical methods combined with our above explained tracing methods, to locate the nearest available next-of-kin at a current address. Vestigium provides this information and details of the relationship of the next-of-kin to the deceased customer (e.g. sister/niece/spouse etc.).
3. Vestigium Holistic Solution
Vestigium takes the full customer file and runs a regular ‘Living as Stated’ check provided by our software supplier. This provides negative assurance only; ‘there is nothing that we are aware of that leads us to believe that the customer has moved location or died. It is recommended that this is carried out annually or twice annually.
Following this check there will be customers records highlighted where there is some evidence of change. These records can then be subject to a full forensic trace as per (1) above.
The Regulators Expectations
The FCA’s Final Guidance (16/8) on the Fair Treatments of Long Standing Customers implies that they expect firms to proactively minimise new Gone Aways whilst understanding the key drivers to achieving a reduction in historic Gone Aways, not simply by periodically repeating the same process but taking effective steps to re-establish contact with their customers.
It is not surprising that the FCA has recently launched its consultation on the Fair Treatment of Vulnerable Customers. Such customers may well represent a significant number amongst Gone Aways at some firms.