TRANSPARENCY FOR CUSTOMERS
Main documents offering products and services, prepared based on requirements of clarity and comprehensibility, are available at branches and online, on the Bank's website, in the section Banking Transparency [i]. In particular, the Information Sheets of the products and services offered, specific Guidelines (Current Accounts, Mortgages, Consumer credit) and Documents on conditions offered to customers are made available.
Since November 2016, information sheets have been aligned with new laws on transparency concerning secured credit and consumers, and the Lending Directive which establishes, in particular, new requirements for consumer assistance, information procedures with “General information” replacing “information sheets” and the addition of three new cost indicators besides the TAEG.
INVESTMENTS: ADVISORY SERVICE
In line with the 2007 MiFID Directive, Intesa Sanpaolo opted to give all its customers the chance to use its advisory service – which offers the highest level of protection for customers – in order to have personalised advice in making investment decisions. Offering advice means reflecting on the needs of customers and their assets as a whole, proposing customised recommendations consistent with their Financial Profile. To support investment choices, Intesa Sanpaolo has developed Recommended Portfolios that originate from a process of analysis that selects and combines the products and services offered by the Bank according to consistency with the market scenario and customer risk profiles. The combination of products and services in the Recommended Portfolios seeks to ensure diversification by market and by instrument, using both asset management and assets under administration products/services.
In 2014, a new European Directive and regulations were issued, introducing major changes. Intesa Sanpaolo started a Project to align with the regulations for the starting date envisaged (3 January 2018). In December 2016, Group Product Governance Guidelines on financial and banking products for retail customers were adopted. Although the legal context is still developing, the Guidelines introduce new processes to protect the interests of customers during the entire life cycle of products.
From as early on as 2015, the Bank carried out a complete overhaul of its profiling questionnaire aimed at obtaining, in advance from the customer, information on their knowledge of and experience in investments, their financial situation and investment objectives.
The new questionnaire – developed further in 2016 – significantly revised the profiling methodology adopted by the Bank, as the process to obtain information from customers has changed from assessment based on self-statements to an evaluation of information already available to the Bank, in terms of customer experience and assets, and includes questions which are not based on self-evaluation and instead mainly refer to “objective” parameters (such as education, profession, dependent family members, income, etc.).
NEW PRODUCTS AND SERVICES: COMPLIANCE CLEARING PROCESSES
Intesa Sanpaolo adopts a “Compliance Clearing” process in developing new products, services and activities with operational and/or reputational risk. The process involves various entities (e.g. Marketing, Compliance, Risk Management, Legal) that give a technical opinion. The “Model to approve new products, services, the start of new activities and investments in new markets” defines the responsibilities, duties and main processes for the Bank and all Italian and international Group Companies in the prior assessment of risks originating from the introduction or revision of a new product or service, the start-up of new activities and entry on new markets in relation to applicable laws.
Since 1 October 2016, interest on deposits and credit transactions between intermediaries and customers has been regulated by new laws which establish that accrued interest payable in these transactions cannot produce interest, save for interest on arrears.
The new rules, which define the frequency for calculating and requesting payment of interest for current accounts and relative credit openings, have introduced considerable changes that also require customer authorisation.
Intesa Sanpaolo has facilitated this change, paying particular attention to notices to customers so that they include various options in a balanced way, representing the various advantages and disadvantages for the customer.
At the same time, a detailed communication and update plan for customer managers was prepared, for them to provide the best assistance possible.
RELATIONS WITH CONSUMER ASSOCIATIONS
Intesa Sanpaolo has long been involved in engagement activities with Italy's leading Consumer Associations, from receiving applications/appeals to finalising cooperation initiatives at a design, technical and operational level.
In 2016, Intesa Sanpaolo renewed its shared commitment to consolidating an economic/banking and consumer culture with the “Mettere in Comune competenze” (Sharing Expertise) project (see “Growing with our stakeholders: a financial culture for informed choices” page 75) and “Final Settlement” (see the website “Settlement Agreement” [i]) as a method of out-of-court settlement adopted and managed together with Consumer Associations.
The settlement procedure, which concerns products offered to retail customers (current accounts and linked payment cards, mortgages and personal loans), is simple, free and fast, with maximum case resolution times of 60 days. Customers may decide to participate, at no cost and without compromising any other procedures they may wish to take subsequently, in order to protect their own interests. During 2016, 40 new applications for final settlement were received.
Concerning the technical debate on specific issues of global significance, the Bank offered to establish technical working groups focused on credit, savings, digitization and new, important products for households.
FINANCIAL EDUCATION INITIATIVES
On a day-to-day basis, increasingly influenced by decisions connected with finance, credit and welfare, most people come up against growing difficulties in managing their money, not only and not always due to a lack of resources, but above all because of a lack of basic financial expertise.
Numerous initiatives have been adopted by Intesa Sanpaolo, particularly for its future customers (for more details, see “Growing with our stakeholders: financial culture for informed choices” page 75).