September’s Board meeting was a virtual one, with lots to discuss. We started by considering and reflecting on the progress that has been made over the summer with the launch of our consultation on new standards for enforcement, and the workshops and discussions that the team have been leading during the consultation period. It is encouraging to see that consultation responses have already started to come in. The Board is looking forward to discussing all of the responses we receive and reviewing the final standards when it next meets, in October.
The main item on the agenda for this meeting was development of the ECB’s complaints handling process. The headline standards for firms on their complaints handling are already set out in the current consultation but this was the first time that the Board was able to discuss the draft guidance for firms that sets out more detail and how they can demonstrate that they are meeting the standards. We also discussed the draft process for the ECB’s handling of complaints and a process for when people request a review of our decisions.
In our consideration, one of the main areas we focussed on was timeframes for the ECB’s investigation of complaints. We want the ECB to offer swift resolution to complaints, because that is best for everyone. As a result, we intend to set timeframes that are shorter than other comparable schemes and shorter than the ADR Directive requires. However, our timeframes must be realistic and we recognise that resolution of complaints will rely on the timeliness of responses from complainants throughout the process, which we will have limited control over. To ensure there is public accountability for our performance, in addition to a headline timeframe, we agreed that we should also publish our performance in resolving complaints at shorter increments.
All of these complaints documents will be further developed and discussed with stakeholders over the coming months. We plan to consult formally on them all in October, so that they can be finalised in advance of our complaints scheme going live in January 2025.
We moved on to a facilitated session on political engagement, where we discussed a strategy for engaging the new Government in the ECB’s mission and securing support for giving the ECB appropriate legal powers in the coming years. There is good alignment between the ECB’s mission and the strategic priorities and missions of the new Government, which means we have a compelling offer to put to Ministers. Our recent work in this area has also reinforced the overall importance of external affairs to the ECB’s mission and we agreed to build our capacity and capability in this area over the coming months.
Finally, we agreed a plan for increasing the Board’s resilience through recruiting an additional Board member and staggering Board members’ terms of appointment so that future changes of the composition of the Board can be well managed.
It is clear that a lot has been achieved over the summer – and there remains a lot to do over the coming months, as we finalise our standards and complaints process, as well as getting ready to launch the re-accreditation process and welcome in-house teams for the first time. Once again, I would like to express my gratitude to everyone who has been contributing their views and expertise to our work to get us to this point and for your ongoing collaboration and support.
Catherine Brown, Chair