1. PPI UPDATE
JULY 2017
Contact:

2. 2 Current position commission / profit share calculation
months until the new rules come into force
consumer awareness campaign
increased queries, complaints, FOS referrals
commission / profit share calculation
judicial Review

3. ? Consumer awareness campaign Types of product that might have had PPI
Encouragement to check if they had PPI
Typical complaint handling times
Website / helpline / video ?
Plevin and undisclosed commission
What PPI and mis-selling is
How to check if they had PPI
FCA / FOS / FSCS
Previously rejected may now be due redress
Template complaint form
How to make a complaint
CMCs and link to register

4. Consumer awareness campaign
Make people aware PPI is relevant to them
Help them check or make a complaint
Awareness of the deadline
Focus on vulnerability

5. Consumer awareness campaign
The specific content of the website / advertising isn’t yet known and won’t 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.

6. Consumer awareness campaign
Five bursts of activity:
End August - November 2017
April – May 2018
October 2018
February 2019
May – August 2019

7. 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

8. 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

9. Judicial Review
We Fight Any Claim have obtained legal opinion on the proposed rules which is they are “probably unlawful” because:
The consultation paper doesn’t 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 FCA’s 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 FCA’s 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
16%
distribution costs, including a reasonable profit margin
average distribution cost
£100

10. 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