BlackRock is pleased to have the opportunity to respond to the Financial Conduct Authority s CP 14/30 Improving complaints handling consultation.

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1 Samuel Condry Strategy and Competition Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS By 12 Throgmorton Avenue 13 March 2015 Dear Mr Condry, Re: CP14/30 Improving complaints handling BlackRock is pleased to have the opportunity to respond to the Financial Conduct Authority s CP 14/30 Improving complaints handling consultation. BlackRock is a leading provider of asset management, risk management, and investment advisory services to institutional, intermediary, and individual clients worldwide. As of 31 December 2014, the assets BlackRock manages on behalf of its clients totalled 2.99 trillion across equity, fixed income, cash management, alternative investment and multi-investment and advisory strategies including the ishares exchange traded funds. BlackRock has a pan-european client base serviced from 22 offices across the continent. Public and private sector pension plans, insurance companies, third-party distributors and mutual funds, endowments, foundations, charities, corporations, official institutions, banks and individuals invest with BlackRock. BlackRock represents the interests of its clients by acting in every case as their agent. It is from this perspective that we engage on all matters of public policy. BlackRock supports policy changes and regulatory reform globally where it increases transparency, protects investors, facilitates responsible growth of capital markets and, based on thorough cost-benefit analysis, preserves consumer choice. BlackRock supports the Financial Conduct Authority (FCA) in its efforts to ensure that the process of complaining is straightforward, transparent and fair to consumers, whilst allowing firms such as BlackRock to handle complaints as efficiently as possible and for consumers to have effective access to the Financial Services Ombudsman if they remain dissatisfied. We welcome the opportunity to address, and comment on, the issues raised by this consultation and we will continue to contribute to the thinking of the FCA on any specific issues that may assist in improving complaints handling. Yours sincerely, Alison Sewell Co Lead EMEA Compliance alison.sewell@blackrock.com Registered in England No Registered office: 12 Throgmorton Avenue,.

2 Key points BlackRock is supportive of the FCA in its efforts to ensure that the process of complaining is straightforward, transparent and fair to consumers, whilst allowing firms such as BlackRock to handle complaints as efficiently as possible and for consumers to have effective access to the Financial Services Ombudsman if they remain dissatisfied. BlackRock strongly believes that when publishing data about the number of complaints received in a certain period the details should include data regarding a firm s volumes, such as the number of clients and / or trading volumes. This would allow clients to reflect on the performance of the firm in relation to its size and complexity and that of its peers. BlackRock believes that the proposal to send written confirmation for complaints resolved within 3 business days creates additional bureaucracy and costs that does not add to the client s awareness and may be considered by clients to be unwanted communication serving no additional purpose. Registered in England No Registered office: 12 Throgmorton Avenue,.

3 Responses to questions 12 Throgmorton Avenue Q1: Do you agree that the time period for firms to resolve complaints informally should be extended from the close of the next business day to three business days (following receipt)? We make every effort to resolve complaints swiftly and where possible within the next business day time period. We will continue to operate on this basis, believing that client expectations are that issues should be dealt with promptly but welcome the extension for dealing with complaints informally to three working days. Q2: Do you agree that firms should report to us, and publish, all complaints that they receive? We have no objection to reporting all complaints to the FCA. However, we firmly believe that any published data should be presented with appropriate context. For example, where an absolute number of complaints is published we would like to see this presented within the context of data that provides a clear indication of the scale of the firm, and overall number of clients. Q3: Do you have any comments on our proposals to improve consumer awareness by requiring firms to send a summary resolution communication in respect of complaints handled within three business days? We see no added value in issuing a written response to a client. We feel that this additional documentation is bureaucratic and may be considered so by the client. In our current practices, we proactively seek to resolve complaints promptly and have adequate records to demonstrate the satisfactory resolution of a complaint. Q4: Do you have any comments on the proposed new complaints return? We support the FCA s efforts to provide greater context and transparency to the client and we have no objection to providing the data in the revised format. Given the additional costs that firms will incur in providing the proposed level of detail we would like to understand from the FCA the cost benefit analysis that has been undertaken to support the proposed changes. Q5: Do you agree with our proposed approach to data contextualisation? We support the FCA s efforts to provide greater context and transparency for clients and we have no objection to providing the data in the revised format. Given the additional costs that firms will incur in providing the proposed level of detail we would like to understand from the FCA the cost benefit analysis that has been undertaken to support to clients of the proposed changes. Q6: Do you have any comments on the new complaints publication report? Please see our comments regarding the contextualisation of any published reports (question 5). Q7: Do you have any comments on these changes (reporting form and guidance)? We have no objection to providing the data in the revised format. Registered in England No Registered office: 12 Throgmorton Avenue,.

4 Q8: Do you agree that all post-contract telephone calls to financial services firms should be charged at no more than a basic rate? We believe that this change would be beneficial for clients but would seek to ensure that financial services firms are provided with an adequate lead time in which to implement this change. This time will be necessary to ensure they have time to undertake a comprehensive review and to update all supporting client communications with any revised contact information. Q9: Do you agree with our proposed amendments to DISP 2.8.1? We believe that clients should be encouraged to seek resolution with respective firms in the first instance. This would prevent duplication of effort where firms are investigating and resolving an issue that may well be settled amicably without recourse to an Ombudsman. Q10: Do you agree with our proposal to retain the existing six month and six and three year time limits for complaints made to the ombudsman service? Q11: Do you agree that once a firm has consented to the ombudsman service considering a complaint it should not be permitted to withdraw consent? Q12: Do you have any comments on the proposed wording firms will be required to include in final response letters? We believe the proposed wording to be clear and that it will meet client expectations. Q13: Do you agree with our proposal to extend the definition of eligible complainant so it is consistent with the ADR Directive? Q14: Do you have any comments on the new rules in DISP 5 that apply to the ombudsman service s annual reports? We have no comment. Q15: Do you agree with our proposed revision of the dismissal grounds in order to bring them in line with the Directive? We believe that consistency with the Directive is important. However, we would like to highlight to the FCA that the reduction of the reasons for dismissal being proposed is in our view not immaterial. In particular, the removal of investment performance complaints and those relating to the legitimate exercise of a respondent s commercial judgement from the Financial Ombudsman option for dismissal of complaints could potentially have a significant impact on firms, therefore not be immaterial. Q16: Do you agree with the proposal to amend the test case rules in this way? We agree and believe the consistency with the Directive is important. Q17: Do you have any comments on the proposed wording for this rule? We have no comments on the proposed wording. Registered in England No Registered office: 12 Throgmorton Avenue,.

5 Q18: Do you agree with our proposed amendment to DISP on the timing of complaints procedure disclosure for intermediaries within the scope of the MCD? Q19: Do you have any comments on the possible impact of this proposal on vulnerable consumers? We believe that the proposals are designed to be beneficial to all clients and we therefore welcome them. Q20: Do you have any comments on our cost benefit analysis? With regards to the areas of reporting and publishing complaints, summary resolution communications and additional complaints return data it is our view that there could be increased costs to firms. As we have already highlighted in our response, we would seek to obtain further explanation on the benefits to the client of these proposed changes. We look forward to these matters being reconsidered prior to implementation. Registered in England No Registered office: 12 Throgmorton Avenue,.