Data, data everywhere, but not a prompt to think 

Hopefully, you won't struggle too much to spot the rather clumsy rendition of "water, water everywhere, but not a drop to drink".  This was, oddly, the first line to pass through my rapidly overheating brain as I filed the twenty-first CMC claim letter to hit one of our Member Firms over the last couple of years.  This is a firm which has (a) never sold PPI, (b) never dealt with the Lenders in question, and (c) who doesn't have as clients, those individuals named on the complaint notification.

What it does have, is a trading name which, on a dark night, assuming one is struggling with a severe ophthalmic condition, bears a passing resemblance to a quite different firm, the kind which might well have been active in the PPI market.  But that's it.  The clients are located elsewhere in the UK, and the kinds of 'finance' being transacted bear no relation to the kind of work undertaken by our long-suffering Member.

It is, for me, a never-failing source of mystery that not only the CMCs, but also the customers themselves apparently never query the substantial, tottering pile of data-anomalies which are the inevitable result of this inept tactic for apportioning blame.  If my search produced names that bore some resemblance to each other, I would have thought that my first action would be to check the details on the FCA Register - such an action would swiftly introduce some much-needed precision to the whole exercise.  Access is free, and it takes thirty seconds to do the job - but, for these CMCs, even that appears to be too much to expect.

I have come to the conclusion that the firms and the customers concerned in this farce simply don't care.  There is a kind of baseline informational threshold which suffices to prop up a kind of grim, cynical, pragmatism which is focused on extracting cash from someone, anyone who might be 'fitted up'.  And then there is a supplemental standard which would be required if the integrity of the whole process actually mattered.  That second tier is usually conspicuous by its absence.  And when we respond to those firms which are so swift in the promulgation of error, one often is given the impression that we are being somewhat small-minded, and mean-spirited in insisting that matters get corrected.

The issue of truth seems to me to matter very greatly.  It is not just a function of dots of graphite on a page, or pixels on a screen, for (as we know, if we've been watching the recent BBC drama, 'The Capture') such things can easily be manipulated.  'Truth' has a great deal to do with the relationship of facts to each other, and with that recognition comes the need to apply the requisite disciplines to ensure that we handle information responsibly and reliably.  The actions of these CMCs betray a culture where this does not happen, where (instead) data is weaponised in order to create mayhem and escalate costs for unconnected parties.

The subversive handling of data that I have described above is actually quite widespread.  We find it in public consultation exercises within local government, where institutional (or, more usually, ideological) presuppositions skew the analysis of data, right from the get-go.  We've seen it recently in FCA reviews, where the 'analysis' generated bears precious little resemblance to the information supplied.  And, of course, it is ever-present in the way in which the FOS goes about its strange, arcane work.  It is, however, all-too easy to point the finger at other parties.  The life-blood of independent financial advice lies not only in having good data to work from, but also in knowing what to do with it.

For ValidPathers...

There's a whole pile of guidance & resources to help you enhance your skills and processes in this area


 

Kevin Moss, 14/10/2019