FOS Training? What Training? When the Investigator Asks Us for the File…

There’s a particular kind of institutional decline that doesn’t arrive with a bang. It arrives with an email. Polite. Earnest. Completely, catastrophically wrong.

This week, we had a fresh batch of examples of what can only be described as the Financial Ombudsman Service operating with its headlights off again, when a new investigator was assigned to our GAP insurance complaints and, brace yourself, asked us for the case file.

Not the seller.
Not the lender.
Not the business being complained about.

Us.

The complainant’s representative.

If you’re wondering whether that’s how any remotely functional ombudsman process works, let me save you the suspense, it isn’t. The file is requested from the respondent firm, not the representative. This is basic day one training, and FOS is getting it wrong and letting these people loose to investigate consumer complaints.

And it’s not a harmless slip. It’s a symptom.

The Basics – Who Holds the File?

Let’s start with the part that should be so obvious it shouldn’t need typing:

In a complaint, the seller and/or lender hold the sales documentation, disclosures, commission data, call recordings, and internal notes. They are the parties who arranged the product, received the money, and built the paper trail. If the investigator needs the file, the correct direction of travel is:

FOS → Seller/Lender → File → FOS → Fair investigation

Not:

FOS → “Hi, can you send us the file?” → Complainant

That’s not investigation. That’s outsourcing. And to the party with the least access to the underlying records.

So what does it tell us when a front-line investigator begins a case by asking the wrong person for the core evidence?

Only two possibilities:

• They don’t understand the process, or
• They don’t understand the product, or
• (Bonus option) They don’t understand either, but have still been placed in charge of the outcome.

None of those are acceptable for an organisation that is, for the majority of consumers, the last stop in their pursuit of justice.

GAP Insurance Isn’t “Exotic” — FOS Shouldn’t Be Treating It Like a New Species

GAP insurance complaints are not fringe. They are not rare. They are not a niche hobby pursued by a small underground community of claims handlers.

GAP is a mainstream, high-volume add-on product, historically sold aggressively and often bundled with finance. It sits squarely in the arena of:

• value,
• suitability,
• disclosure,
• conflicts of interest,
• commission,
• and whether the consumer understood what they were paying for (and why).

If FOS cannot competently triage something as fundamental as ‘who holds the file’, we are forced to ask what chance is there that the investigation will properly grapple with the actual issues?

Because the issues aren’t difficult to state:

• What did the consumer pay, end-to-end?
• What did the underwriter receive (the actual risk cost)?
• How much was swallowed by commission and distribution?
• Was that properly disclosed?
• Was the product fair value?
• Was it sold in a way that was fair, clear, and not misleading?
• Was it suitable for the consumers needs?

You don’t get to a fair answer by starting the process with a scavenger hunt.

“These Employees Should Be Nowhere Near the Front Line”

That sounds harsh. It is harsh. And it’s true.

There is a minimum competence threshold required to investigate complaints that can materially affect lives, businesses, and financial outcomes. When that threshold isn’t met, the damage is not theoretical:

• Consumers wait longer.
• Firms incur needless cost responding to confused requests.
• Evidence goes missing or is never properly obtained.
• Decisions are made on incomplete records.
• Complaints are mishandled, delayed, or “resolved” on procedural misunderstandings rather than substance.

A complaint investigation is not an apprenticeship in real time, carried out on the public.

If FOS is placing inexperienced investigators into complex complaint streams without adequate training, mentoring, or supervision, then FOS isn’t merely underperforming. It is structurally failing the very purpose it exists to serve.

The Leadership Problem. This Isn’t a One-Off, It’s Systemic

Let’s be blunt, this simply doesn’t happen in a well-led organisation.

It’s not just “a new investigator asked a silly question.” It’s why that question was asked, how that investigator was deployed, and what safeguards apparently weren’t in place to stop the basics being missed.

Competent leadership would ensure:

• clear investigation checklists,
• product-specific training (GAP is not new),
• escalation routes,
• supervision,
• quality assurance,
• and a culture where asking for core evidence follows a defined, correct process.

So when we see elementary errors, we don’t just see an individual mistake. We see:

• inadequate onboarding,
• weak supervision,
• overwhelmed teams,
• and an organisation trying to process volume while quietly misplacing competence.

And that is not an insult. It is an observation, based on what FOS is doing in real world cases.

The All-Time Low Problem – Standards, Knowledge, and the Cost of “Good Enough”

FOS has a public role. It holds a privileged position. It influences industry behaviour and consumer outcomes. It is supposed to be the place where fairness is applied with care and consistency.

But fairness requires two things FOS increasingly appears to be struggling with… strong understanding and an attention to detail.

This isn’t complicated, and competent leadership, processes and training would’t allow anything less.

And yet the system seems content to run on “close enough,” while consumers are left waiting and firms are left frustrated, with both sides paying the price for procedural incompetence.

A Simple Test FOS Should Apply to Itself

Before assigning an investigator to any complaint stream, FOS should be able to answer:

• Do they understand the product?
• Do they understand the evidence chain?
• Do they understand who bears which obligations?
• Do they know what documents are required as standard?
• Do they understand commission structures enough to ask the right questions?

If the answer is “not yet,” that employee should not be conducting front-line investigations. They should be in training, shadowing, and supervised, not steering outcomes.

Because the public doesn’t need a learner driver at the wheel of an ombudsman decision.

If the organisation is overwhelmed, the honest answer is to admit it, resource it properly, and stop pretending the solution is to place undertrained staff on the front line and hope nobody notices.

We notice.

Final Thought. If This Is the Start, What Does the End Look Like?

When the opening move in a complaint investigation is “can you send us the file?” asked of the wrong party, it raises a serious question:

If this is the standard at the beginning, what confidence can anyone have in the decision at the end?

Because consumers deserve better than this.

And if FOS is now at an all-time low on standards and knowledge, it’s not merely disappointing.

It’s dangerous.