PPI UPDATE JULY 2017 Contact: 020 3176 5713 [email protected] k Current position 2 months until the new rules come into force consumer awareness campaign
increased queries, complaints, FOS referrals Consumer awareness campaign Types of product that might have had PPI Encouragement to check if they had PPI Website / helpline / video
What PPI and misselling is FCA / FOS / FSCS Plevin and undisclosed commission How to check if they had PPI Template complaint form
How to make a complaint CMCs and link to register Previously rejected may now be due redress Typical complaint handling times ?
Consumer awareness campaign Awareness of the deadline Make people aware PPI is relevant to them Focus on vulnerability Help them check or make a complaint
Consumer awareness campaign The specific content of the website / advertising isnt yet known and wont be shared with firms ahead of the launch. There is already an information sheet outlining the new basis for making a PPI complaint as well as a link to the PPI complaint form used by FOS. Consumer awareness campaign Five bursts of activity: End August - November 2017
February 2019 April May 2018 May August 2019 October 2018 Incoming contact volumes Firms expecting complaints between 60%-80% of the previous peak; some firms planning for 100% FCA anticipating 1.13m weekly hits to their website with the highest levels in the first 6 weeks
FCA not setting targets for complaint numbers Some firms already seeing increased activity from CMCs and Resolver Commission and profit share Governance Appropriate seniority Independent validation Data gaps Subject matter experts, e.g. finance / legal All reasonable attempts made Rates close to the tipping point / outliers Indicator something is wrong Other sources of income Loyalty / volume payments Investment income / paid administration not included
Judicial Review We Fight Any Claim have obtained legal opinion on the proposed rules which is they are probably unlawful because: The consultation paper doesnt contain sufficient information for people to comment on how well the communication campaign will make consumers aware of their rights The deadline is in breach of the Equality Act and incompatible with the FCAs general duties The rules impose a time limit which excludes complaints to a tranche of PPI sales for which s140A of CCA applies The 50% tipping point fails to apply the Plevin principle and is inconsistent with the FCAs general duties The proposed level of redress is inconsistent with the principle of putting the customer back in the position they would have been in
Wider FCA views Previously rejected mailing only needs to be sent by the seller who has investigated a mis-sale complaint All previously rejected customers must be mailed, regardless of whether they are above or below the tipping point Previous complaints which have been upheld (with or without redress) are excluded from the mailing and from any step 2 investigation No changes to DISP reporting
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