Complaints handling for insurance brokers: what I learned

Most people in financial services avoid complaints work. Not because they don't care about clients — most of the people I have worked alongside over the past eleven years genuinely do. They avoid it because it is uncomfortable, because the outcomes are uncertain, and because there is a specific kind of dread that comes with calling someone back when you already know the answer is not what they were hoping for.

I avoided it for a year. Actively. Repeatedly. And I want to explain why — and what changed when I finally stopped.

What a Customer Advocate actually does

The title sounds formal. The work is not glamorous.

A Customer Advocate receives complaints, investigates them, and responds to them. They sit between the client and the business, gather the full facts from all relevant parties, and then make a determination — or present one to the decision-maker — about what happened, whether it was handled correctly, and what, if anything, needs to change.

In an insurance context that might mean a client who is unhappy with an underwriting decision. A billing dispute they don't understand. A claim they feel was handled unfairly. A renewal they weren't given enough notice on. A broker they feel didn't listen to them.

The Advocate investigates all of it. They read the file, review the correspondence, speak to the colleagues involved, and then call the client back. Sometimes the determination is that the company was wrong and something needs to be corrected. Sometimes it is that the company acted properly, the expectations were set correctly, and the decision stands.

Both outcomes require the same thing: that someone took the complaint seriously, investigated it thoroughly, and communicated the result with honesty and care.

That is the job.

The year I kept saying no

When I was at CUMIS, the Customer Advocate team kept asking me to join them.

By that point I had nine years in the industry. Good performance reviews. A CIP designation. I knew how to read a file, how to talk to underwriters, how to explain a billing charge to someone who was confused or frustrated. On paper I was a reasonable candidate.

I still said no. Every time.

The honest reason was fear. I am, by nature, a people pleaser. The idea of calling someone to deliver news they didn't want to hear made me cringe before I had even picked up the phone. I was afraid I would freeze. Afraid I would cave when I shouldn't. Afraid I would disappoint someone and not be able to live with it.

So I declined, and found reasons why it wasn't the right time, and watched other people do the work instead.

In 2021 I finally said yes. Not because the fear went away. Because I got tired of letting it make decisions for me.

What I found on the other side

The calls I dreaded most were the ones where I already knew the answer was no.

Not because I hadn't tried. I had. I had read the file, spoken to the underwriter, made the case as well as I could make it, and still couldn't get a different outcome. The risk didn't meet the criteria. The underwriting decision was sound. The billing charge was correct. There was nothing to change.

What I learned is that the call doesn't end there. Not if you're doing it properly.

You deliver the decision clearly. You explain the reasoning without hiding behind policy language. You let the client respond and you actually listen — not wait for them to finish, but listen. And then you ask yourself one more question: what would I do if I were them?

Sometimes the answer was a suggestion about steps they could take to improve the risk. Sometimes it was pointing them toward a specialist market better suited to what they needed — a high-value RV, for example, is often better placed with a specialist insurer who genuinely understands that risk than with a standard book that will underwrite it reluctantly. The client didn't always leave with what they came for. But they left knowing someone hadn't stopped working for them when the easy answer ran out.

And here is what surprised me most: the calls I had dreaded, the ones where I had prepared to deliver bad news, almost never ended badly. The client would listen, ask questions, and then say something like: thank you for looking into this properly. I appreciate that you tried.

That response taught me something I have not forgotten.

A client who complains is not your adversary. They are a client who still expects something from you — which means they have not given up on you yet. That is loyalty. Most brokers, when a complaint lands, go into defence mode. The instinct is understandable. It is also usually the wrong move.

The things that actually determine how a complaint ends

Get in front of it early.

A complaint handled within 48 hours, with genuine investigation and a clear follow-up, rarely escalates. The same complaint left to sit for a week becomes a different conversation. Clients complain because they expect better — take 48 hours, investigate properly, and call them back. By the time you call, they have usually moved from a ten to a four. They are ready to talk, not fight.

Know the file before you call.

Before you pick up the phone, read everything. What was said, what was decided, what was promised, what expectations were set. Understand the client's profile. Know the full picture before the conversation starts. If you go in underprepared, you will either say something you shouldn't or be caught out on a detail you should have known. Neither helps.

Notice your own bias and set it aside.

There is a Japanese Zen teacher, Shunryu Suzuki, who wrote something that has stayed with me,

in the beginner's mind there are many possibilities, but in the expert's there are few.

What he meant is that certainty closes us off. The more convinced we are that we already know what happened and who was right, the less clearly we see the situation in front of us.

The bias, the defensiveness, the ego that shows up when someone challenges a decision you made — that is not a character defect. It is human. You cannot eliminate it. What you can do is notice it, acknowledge it, and choose how you respond anyway. Going into a difficult conversation as if you already know how it ends is the fastest way to make it worse.

Loop in everyone relevant.

Brief your colleagues. Speak to the underwriter, the billing team, the person who took the original call. Gather all the facts before you form a view. Investigate with genuine curiosity rather than looking for evidence that supports a conclusion you've already reached. If there was a breakdown somewhere, this is how you find it.

Keep the client informed throughout.

If a resolution is taking longer than you expected, tell them. Radio silence turns a four back into an eight. A simple message that says I'm still on this, it's taking a little longer than I expected, I haven't dropped it — that keeps trust intact. It also keeps the complaint from escalating to the Financial Ombudsman Service, which is where you do not want it to go.

Be a fair human, not a corporate function.

Regulators, ombudsmen, and judges look at the spirit of what was communicated, not just the letter. If a client had a genuine and reasonable belief based on what was said to them, you have to be willing to take that seriously. The goal is not to win. The goal is to reach a fair outcome, document it properly, and move forward.

Be solutions-focused.

Do not get pulled into the drama of who said what and when. Let the client vent — that is appropriate and necessary — but stay anchored to what a resolution looks like. Speak in outcome language. Here is what I am going to do. Here is what I think a fair result looks like. Here is what I am aiming for. Promise only your best effort and your thoroughness. Never promise an outcome you cannot control.

The thing most insurance brokers handling complaints are not doing that will cost them

Documentation.

I want to be direct about this because it matters more than almost anything else in this piece.

Documentation is not what saves you during a complaint. It is what saves you before one ever becomes serious. The notes you take on an ordinary Tuesday afternoon, the call you log properly, the email you summarise and attach to the client record — that is the evidence base you will be grateful for when someone disputes what was agreed six months ago. I wrote about this in more detail in a recent post on client file and CRM data hygiene.

I have never seen a well-documented file lose a complaint it deserved to win. I have seen poorly documented files lose complaints that should have been straightforward — because without a clear record, you are arguing from memory against someone else's memory.

That is not a position you want to be in. Under the FCA's DISP rules, you have eight weeks to issue a final response to a complaint. That clock starts the moment the complaint is received. If your file is incomplete, you are investigating under time pressure with incomplete evidence. The process becomes harder than it needs to be.

And if the complaint goes further — to the Financial Ombudsman Service — the stakes become financial as well as reputational. The FOS charges a case fee to the firm regardless of the outcome. You can do everything right, the determination can go in your favour, and you still pay. Prevention is not just good practice. It has a direct cost attached to it.

Good documentation is your first line of defence against ever getting there.

If you are doing virtual meetings with clients, transcribe them and put the transcript in the file. The technology is fast and it captures detail that even careful notes miss. Be mindful of what data you are sharing with AI transcription tools and make sure you understand the compliance implications before you use them — but use something. Document during the call if you can. Document immediately after if you cannot.

Your future self — the one on the phone at 4pm on a Friday trying to remember what was agreed eight months ago — will thank your past self for it.

Why I am writing this

I spent years doing this work inside the industry — representing clients, holding the line when the facts supported it, finding another door when they didn't. Complaints handling for UK insurance brokers is a significant part of what I bring through UK Broker Support — not as a formal function, but as operational experience built over eleven years of doing the work.

Not because I can promise a client will always be happy with the outcome. Sometimes the answer genuinely is no and the right thing to do is explain why clearly and stand behind it. But because I know how to make sure the client feels heard, that the facts were gathered properly, that every relevant party was spoken to, and that the decision — whatever it was — was made for the right reasons and documented in a way that speaks for itself.

For a founder-led brokerage, a complaint that is handled well is an opportunity to demonstrate exactly what your practice stands for. A complaint that is handled poorly — or ignored, or defended without investigation — is a reputational and regulatory risk that compounds quietly until it isn't quiet anymore.

If you are carrying a version of this problem in your practice right now, or if you want to talk through what proper complaints handling looks like operationally, I would like to hear from you.