2. Client Care

Question 1

What are your two Client Care SoE examples?

Answer 1

L2 Example – ‘Information Requirements Document’, Dev loan Hackney (Wilmer Place)
L2 Example – Tenant consultation, Affordable Housing Portfolio Acquisition (Project Bluebell)

Question 2

What is client care?

Answer 2

• Client care is the process of delivering a professional service that meets or exceeds client expectations.
• It involves
  1) clear communication
  2) understanding client objectives, 3) proactively managing relationships
  4) responding effectively to feedback or complaints.
• RICS expects members to act with integrity and provide a high standard of service, as outlined in the RICS Rules of Conduct.

Question 3

How do you confirm your client’s objective early on?

Answer 3

• For clients Funds (e.g., OHF, OAHF, CREDF): I review the Private Placement Memorandum, which outlines investment strategy, return expectations, risk profile, and target assets.
• For borrowers in lending transactions, I arrange an initial call to understand lending requirement (amount), most critical factors, their timelines, and explain our typical approval process.
• Might use STAR framework: Situation Task Action Response

Question 4

What is your company’s client care guidelines?

Answer 4

Customer service – Octopus USP & common strand across all business departments.

Octopus’ client care approach is centered on:
* Clear, jargon-free communication
* Tailored and proactive relationship management
* Complaint resolution with empathy and efficiency
* Ensuring all staff follow the Octopus Complaints Handling Procedure
* Transparency and ethics, in line with FCA’s Consumer Duty principles (regulated) - we treat regulated and unregulated financial products with the same level of care.

Question 5

What is Octopus’ Complaints Handling Procedure?

Answer 5

• Octopus is regulated by the Financial Conduct Authority.
• Complaints must be acknowledged within 2 working days.
• A full investigation is undertaken and a final response issued within 8 weeks.
• If unresolved, the complaint can be referred to the Financial Ombudsman Service (FOS).
• All complaints are logged and reviewed to identify patterns and improve service delivery.

Question 6

What is the FCA’s regulation on complaints handling and how does it differ to RICS?

Answer 6

FCA:
1. Acknowledge complaint within 2 working days
2. Provide a final written response within 8 weeks
3. Must be clear, fair, and not misleading
4. Inform client of right to escalate to FOS
5. Maintain complaint records for at least 3 years

RICS:
1. Requirement to have published CHP.
2. Internal review and acknowledge complaint in 7 working days.
3. Investigated in 28 days with response.
4. If unresolved redress to third part resolution: an independent redress mechanism (e.g. the Property Ombudsman scheme).

Question 7

What did you learn in your CPD on Complaints handling?

Answer 7

Octopus complaints handling procedure = annual CPD
* Octopus Regulated by FCA
* At Octopus, regulated and unregulated financial products are treated the same in complaints handling.
* Managing customer expectations is critical.

Question 8

What did you say to the Client the purpose of the information requirements document was?

Answer 8

• To streamline the underwriting process but consolidating requests for all necessary document upfront.
• Required for KYC/AML checks to comply with UK Anti Money Laundering Regulations (2018); Proceeds of Crime Act (2002)
• Also needed from my company’s credit policy standards

Question 9

Was the client’s complaint about providing information a red flag for AML / KYC?

Answer 9

Not a red flag — frustration over volume, not refusal
and after expressing frustration provided info

Question 10

What information was necessary to obtain from the client for AML / KYC?

Answer 10

Legislation:
1) Proceeds of Crime Act 2002 - UK AML Regulations 2017
2) Terrorism Act 2000

Example Case Summary:
* Borrower SPV: Wilmer Place Developments Ltd
* Structure: Simple – SPV owned under developer Topco
* Shareholders: PW (56.5%), Ed Moon (25%), GS (18.5%)
* Only 2 individual AML checks needed (Ed Moon & PW)
* GS & PW were senior executives at and c.5% shareholders in EMIS Group plc, a UK digital health company – sold for in Oct 23 for £1.2B

KYC – Individuals:
* Proof of ID: Valid passport or driving licence
* Proof of address: Utility bill, council tax bill, or bank statement (last 3 months)
* Source of funds / wealth: Declaration or documentation

KYC – Company (SPV):
* Certificate of incorporation
* Structure chart
* Full company name, registration number, registered office
* Identify Director & shareholder details (>25% ownership)

AML Checks – Individuals:
* Tracesmart e-ID – ID verification
* Google – Adverse media / litigation
* World-Check – PEPs, sanctions, watchlists
* Creditsafe/ Experian Director – Directorships, insolvency flags, defaults, CCJs.

AML Checks – Company:
* Creditsafe – Credit score, company status, charges
* Companies House – Filings, ownership, mortgages
* World-Check + Google – Adverse findings, offshore checks (e.g., Jersey registry)

Internal Risk Rating:
* HATAR methodology (Higher Than Average Risk)
* Risk scored: Low / Medium / High
* Medium/High = Escalated to Compliance Team

Question 11

How did you communicate calmy, clearly and professionally the information requirements to the borrower?

Answer 11

• Applied the “Empty Bucket” technique – let the client fully express their frustration before responding
• Used plain English – avoided jargon
• Explained why each item was needed (AML / credit checks)
• Sent a written follow-up summarising verbal explanation
• Reassured them about secure data handling (GDPR compliant)

Question 12

How did you handle the Borrower’s information securely and in like with which GDPR guidelines?

Answer 12

• I applied the principles of lawfulness, data minimisation, and integrity: data was collected and processed only for legitimate AML compliance purposes, I only collected what i needed and I made every effort to avoid data breaches.

7 principles of UK GDPR:
1. Lawfulness, Fairness & Transparency – Process data legally, fairly, and openly.
2. Purpose Limitation – Use data only for specified, explicit, legitimate purposes.
3. Data Minimisation – Collect only what is necessary for the intended purpose.
4. Accuracy – Keep data accurate and up to date; correct errors promptly.
5. Storage Limitation – Retain data only as long as necessary for its purpose.
6. Integrity & Confidentiality (Security) – Protect data against unauthorised access, loss, or damage.
7. Accountability – Be responsible for compliance and able to demonstrate it.

• Data minimisation – only the documents strictly required (such as certified passports and proof of address) were obtained.
• Integrity and confidentiality – information was stored securely on encrypted, access-restricted systems, with password-protected files and no hard copies retained
• securely deleted emails where information had been sent to

Question 13

What are the key principles of the Social housing’s tenant involvement and empowerment standard (2017)

Answer 13

Published by Regulator of Social Housing

• Give tenants accessible, relevant, and timely information.
• Tenants must have a real opportunity to influence decisions and service delivery.
• Give tenants opportunities to complain
• Treat tenants with fairness and respect

Relevant at time of transaction. BUT WAS REPLACED IN APRIL 2024 by:

The Transparency Influence and Accountability Standard (2024)

Stronger focus on publishing performance data (TSMs) and enabling tenant scrutiny

Question 14

How did you coordinate clear responses to queries from tenants on the change of management provider?

Answer 14

RP changed due to acquisition by my Client’s For-Profit RP NewArch and new management agreement with Southern Housing.

1. Drafted tenant letter
   * Joint branding Octopus / Golding Homes / Southern Housing
   * Clear jargon free explanation of change
   * Reassured tenant: no change in tenancy agreement/ right or housing services
2. Set up direct contact points
   * Dedicated phone line (Southern)
   * Dedicated shared mailbox, coordinated responses
3. Hosted online town hall event:
   * Platform for queries and complaints
   * Only 1 tenant tuned up
   * Offered multiple sessions
   * Provided written follow up
4. Prepared FAQs – anticipated questions

Techniques:
* Active listening and empathetic language in all responses
* Responded promptly and professionally to queries
* Coordinated with Southern to ensure message consistency

Question 15

How did you ensure client care in the online town hall you hosted?

Answer 15

• Clear, early communication – invitations sent in advance with easy access instructions
• Schedules multiple times to maximise attendance
• Used plain English / no jargon
• Reassured tenants of their tenancy rights and no service change
• Provided multiple methods for complaints to be made (phone, online event, email)
• Follow up in writing

Question 16

Did you setup a robust complaint handling procedure for the tenants and what did it involve?

Answer 16

• Multiple channels for complaints: phone, email, online
• Over 3-week minimum consultation period - standard of Regulation (Social housing’s tenant involvement and empowerment standard 2017)
• Timely acknowledgement within 2 working days
• Prompt investigation of all issues raised
• Logged every complaint/question in a tracker
• Coordinated with Southern Housing & Octopus for consistent handling and escalation
• Informed tenants of right to escalate to independent redress (Housing Ombudsman)
• In this case, received a few questions but no formal complaints.

Question 17

What are some /procedures for good client care?

Answer 17

• Understanding your client’s objectives and requirements – define client brief
• Strong communication
• Listening / seeking formal and informal feedback from them.
• Responding speedily to queries
• Having robust complaints handling procedure

Question 18

What are some examples of things that can be implemented to improve client care?

Answer 18

• Complaints handling procedure
• Quality assurance (QA procedures)
• Establishing Key performance indicators (KPIs)
• Client satisfaction questionnaires
• Client feedback meetings
• Lessons learned workshops

Question 19

Why is client care important?

Answer 19

• Aligns with RICS standards and conduct expectations
• Builds long-term relationships with clients – repeat business
• Reduces complaints and risks to the business – reputational damage
• Enhances my professional reputation and maintains trust in the industry

Question 20

Who are all the different clients you have worked with?

Answer 20

• My client funds and their investment/ credit committees
• In lending - Borrowers/ Developers
• In affordable housing – Social housing tenants
• In care home – Care home tenant operators
• In retirement – Purchasers/ Pension Insurance Corporation

Question 21

What is a duty of care?

Answer 21

Moral and legal obligation to act in your client’s best interest with reasonable skill and care.

Making sure you are competent to perform the task in question.

Question 22

What is client empathy?

Answer 22

Understanding the underlying needs and feelings of customers. It puts things into context by viewing things from their perspective.

Question 23

How do you build trust with a client?

Answer 23

• Understand their objectives and challenges
• Only act within my level of competence
• Act in a professional manner
• Provide high level of service
• Transparency- be open and honest

Question 24

What is a stakeholder?

Answer 24

Any individual, group, or organisation with an interest or influence in a project, decision, or outcome

Then give example…