A Part VII transfer is the common name for the transfer of a portfolio of contracts from one entity to another under Part VII (Control of Business Transfers) of the Financial Services and Markets Act 2000 (FSMA 2000). The transfer allows a portfolio of contracts and the associated assets and liabilities to be legally transferred from one entity to another, either within the same group or to an external party.
In early 2012, a global life insurance company was restructuring its UK business with the intention of transferring part of its UK insurance business to an external life insurer and the remainder of its UK business internally to companies within the its own group.
These insurance business transfers – commonly known as “Part VII transfers” – would need to be sanctioned at two High Court hearings, and would require a comprehensive policyholder communications exercise to be completed:
- The transfers would be advertised in the national press
- Information about the transfers would be placed on the company’s UK website
- Nearly 500,000 policyholders would be personally mailed during May/June 2012 to tell them about the part VII transfers. The policyholders to be contacted would include policyholders in 3 European countries, as well as UK policyholders.
The Telemarketing Company was asked to manage the responses to these communications by providing a live inbound call handling service spanning four languages between the hours of 8am and 6pm (Monday to Friday), commencing April 2012 and closing at the end of July 2012.
Based on industry norms, response rates to these notifications were forecast to be ~2% of the policyholders mailed.
Responses from policyholders would include:
- Queries about the Part VII transfers
- Requests for Information (RFIs)
- Objections to the Part VII transfer and / or an intention to attend the Court Hearing; or
- ‘Business as usual’ (BAU) enquiries.
There are strict rules governing the handling of calls in response to Part VII transfer communications, and detailed information about the number and nature of calls would need to be presented as evidence at the High Court hearings.
Project execution and results
Development of an inbound call handling system
A series of meetings were held between the client company and The Telemarketing Company to build a working script that catered for every category of response to the various Part VII transfer communications. A set of Q&A’s was also developed to enable the call agents to answer enquiries relating to the Part VII transfers and to satisfy most concerns / queries the policyholders would have. (Although these Q&A’s were very comprehensive, there would nonetheless be certain occasions when the call agent was unable to resolve the policyholder’s query.)
The big challenge was how best to operationalise the script and Q&A’s to ensure a smooth customer experience and to meet the strict reporting requirements of the Part VII transfer process. As the leading outbound telemarketing company in the UK, The Telemarketing Company was able to leverage its 20 years of experience handling outbound calls to develop a bespoke solution. The CATi platform - which was designed primarily to manage outgoing calls – was cleverly adapted to suit the specific of the Part VII transfer process:
- It enabled the call agents to quickly and accurately verify the identity of the caller. This was essential, as The Telemarketing Company did not have access to the client’s IT systems.
- It ensured that the call agents were able to effortlessly lead the conversation and easily access the correct information to answer policyholders’ queries.
- Whenever a call resulted in an unresolved Part VII query, the system automatically generated an email to notify the client company so that these queries could be dealt with ‘in house’.
- Whenever a call resulted in a BAU query, the system enabled the call agent to provide the policyholder with the correct BAU telephone number to call.
- The system was easily able to cope with multiple outcomes in a single policyholder call (for example, a single policyholder call may contain a Part VII query, a Request for Information and a BAU query).
- Finally, because detailed information about the number and nature of calls would need to be presented as evidence at the High Court hearings, the system was able to capture detailed MI which enabled The Telemarketing Company to produce bespoke statistical data exports regularly and ad hoc.
Set-up and resourcing
A list of 7 Part VII transfer freephone contact numbers were issued to The Telemarketing Company, and routed to numerous DDI’s in the department. Each DDI was attached to a hunt group, enabling the calls to be distributed to a large team of agents.
Call agent resourcing levels were calculated by The Telemarketing Company in accordance with the “Erlang C” formula to ensure that – even during periods of high traffic - the number of unanswered calls was kept to an absolute minimum.
A separate voicemail service was set up for each of the Part VII transfer contact numbers to cater for the calls from European policyholders as well as UK calls. These covered the overflow of any calls that exceeded the number of agents available to handle calls live, and also handled any calls received out of hours.
Call agent training
The Telemarketing Company and the client company joined forces to put a team of 15 agents (spanning four languages) through a rigorous training programme to ensure that:
- they had a good understanding of the client company, the background to the transfers and the Part VII transfer process itself; and
- they were familiar with the script and the IT system they were required to use.
The calling period - results
During the calling period (end of April 2012 to end of July 2012), The Telemarketing Company successfully handled almost 4,000 calls with a peak flow of around 300 calls per day and an overall call answer rate of more than 95%.
Throughout the calling period, The Telemarketing Company supplied the client company with written reports on a daily basis, supported by both verbal and electronic communication. At the end of the campaign, The Telemarketing Company supplied the client company with a full report providing a detailed analysis of the types of calls received and their outcome, together with verbatim responses for any unresolved Part VII enquiries or Objections to the transfer (all of which could be supported with call recordings if required).
This comprehensive reporting enabled the client company to demonstrate that the policyholder responses had been handled in line with the strict requirements of the Part VII transfer process, which was one of the key reasons why the High Court provided its approval for the transfers.
"When we first met The Telemarketing Company we were instantly impressed by the speed with which they got ‘under the skin’ of the brief, and it was an easy decision to appoint them as our Part VII response handling agency.
I was consistently delighted with the service we received from The Telemarketing Company. They displayed great ingenuity in developing an IT platform to meet the very specific requirements of a Part VII transfer communications exercise, and throughout the duration of the campaign they displayed impressive flexibility to cope with our various demands. Nothing was too much trouble.
A key driver behind the success of our campaign was the quality of the call agents themselves. The Telemarketing Company’s policy of maintaining an agent base with above-average age, ability and tenure was in clear evidence, and the agents managed this technically demanding campaign with rigour and professionalism.
The Telemarketing Company are now fully versed in the demands of the Part VII transfer communications process, and I wouldn’t hesitate to recommend them to any company planning a similar exercise. They will certainly be our ‘go to’ agency for any future Part VIIs."
Senior Marketing Manager, Major Global Insurer