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London-based credit card firm NewDay (which was formerly known as SAV Credit) is to pay refunds totalling more than £4 million to some 180,000 customers, after the firm decided the charges they had paid could have been unfair. The firm alerted the Financial Conduct Authority (FCA) to the issue, and the regulator has praised the firm’s “proactive approach”.

This announcement means that around 3% of the firm’s customers will qualify for some form of refund. NewDay undertook a review of its business model, including its charging structure, and concluded that some customers had paid default fees and fees for delayed payments in ways that may have been unfair.

The firm will write to all affected customers before the end of June 2016. In most cases, the refunds will be paid in the form of credits on the customers’ accounts, although a small number of refunds are likely to be paid via cheque.

The redress initiative only covers fees charged on or after April 1 2014 – when the FCA took over as consumer credit regulator. However, any customers charged fees before this date that they believe to be unfair have been encouraged to submit a complaint to the firm.

As well as committing to pay this redress, NewDay says it has changed its criteria over when default fees may be charged, and has set up a system under which customers will be alerted in advance regarding payments due.

Jonathan Davidson, director of supervision – retail and authorisations at the FCA said:

“The FCA welcomes NewDay’s proactive approach to ensuring it treats customers fairly. The FCA expects all firms to consider the fairness and impact of their default fees and charges. It is important that firms, where they identify concerns in relation to their fees, disclose those concerns to the regulator, proactively act on those concerns and keep the regulator informed.

“NewDay has disclosed this matter to us and has committed to putting things right for its customers. Where firms identify unfair overcharging within their policies and systems we would encourage firms to undertake similar initiatives.”

Under the FCA’s rules, a firm can only attempt to impose debt recovery costs on a customer if a formal agreement or contract between the firm and customer allows this to occur. If a firm is contractually permitted to impose default charges on a customer, then the amount of these charges and the circumstances in which they may be imposed should be stated in the agreement. Charges imposed on customers in default or arrears must be no higher than the costs the firm incurs as a result of the customer’s failure to maintain their obligations.

NewDay specialises in providing credit cards to ‘near prime’ customers seeking to improve and repair their credit records. It also provides co-branded cards for well known retail brands, including Debenhams, Arcadia Group, House of Fraser and Laura Ashley.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

Hire purchase retailer Dunraven Finance Ltd, that trades as Buy As You View (BAYV), is to pay £939,000 in compensation to some 60,000 customers. The regulator, the Financial Conduct Authority (FCA) intervened over what it saw as unfair treatment of the firm’s customers. This action follows the findings of a Skilled Person who was appointed to review the firm’s practices.

The firm offers furniture and electronic goods under hire purchase agreements, and was found to have failed to explain its fees sufficiently clearly to customers, and not treated customers in arrears fairly. Many BAYV customers rented television sets based on a prepayment meter, so their TVs switched off when they were deemed to have missed a payment.

Redress will be paid either in cash, or as a balance write down.

• 58,232 customers will receive compensation totalling £706,000 for fees charged for unpaid direct debits, dating back as far as 2001
• 1,610 customers will receive compensation totalling £74,000 for administration fees of between £30 and £45 for a re-financing arrangement used by BAYV between November 2012 and March 2014

The firm has also agreed not to switch off customer’s TVs until 14 days notice has been given of a missed payment.

An additional 3,877 customers will be contacted by BAYV so the firm can ascertain whether they are due any compensation, which could in total amount to as much as £159,000. These customers were all sold additional goods by BAYV under modifying credit agreements, when instead the firm should have drawn up a new agreement for each item. Customers may have paid more under the modifying agreement than would have been the case under a new agreement.

All compensation will be paid by the end of 2016, and the firm will be contacting all affected customers by April 6 2016.

Jonathan Davidson, Director of Supervision – Retail and Authorisations at the FCA said:

“We are pleased that BAYV is working with us to address our concerns.

“It is important that firms meet our standards, including carrying out proper creditworthiness assessments and making sure that those in difficulty are treated fairly. We will continue, when necessary, to take action against inappropriate behaviour.”

BAYV chief executive Graham Clarke said:

“We have worked closely with the FCA in recent months to address these issues and I am sorry to any of our customers who may have experienced difficulties as a result of us not achieving the high standards we set ourselves.

“We have gone further than the recommendations in the review by making additional changes to our operations. As we continue on our transformational journey, our aim is to be the most responsible lender in the sector.”

This may not be the end of the FCA’s action against the firm, as the Skilled Person is now examining credit and affordability checks conducted by the firm, amid concerns that some customers have received amounts in excess of BAYV’s lending criteria. Hence the firm may need to pay additional redress at a later date.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

The Government has confirmed it intends to bring claims management companies (CMCs) under the Financial Conduct Authority (FCA)’s remit. This follows an independent review of the regulatory system for CMCs, although the review did not explicitly recommend this move.

The announcement means that CMCs can inevitably expect tougher regulation once the switchover has occurred, although at present there is no indication of when this will occur.

Financial services firms who are regulated by the FCA are required to comply with an extensive rulebook, are required to submit comprehensive data returns and are subject to a structured monitoring programme. The FCA can also impose bans and fines not only on authorised firms that break the rules, but also on key individuals within firms. For example, in the first half of March 2016 alone, five individuals have been prohibited by the FCA.

The announcement was made as part of the Government’s Budget measures. A Treasury statement referred to the FCA’s policy of holding senior management accountable by saying:

“The Government is clamping down on the rogue claims management companies that provide bad service and bombard customers with nuisance calls.

“The new regime will be tougher and will ensure claims management company managers can be held personally accountable for the actions of their businesses.”

Huw Evans, director general of the trade association the Association of British Insurers, commented:

“For too long the regulation of claims management companies has not been fit-for-purpose, leaving the public at the mercy of unscrupulous firms who make nuisance phone calls and encourage frivolous and fraudulent claims.

“It should go a long way to driving the cowboy operators out of town and helping to ensure honest customers don’t end up footing the bill for their dodgy practices.”

In a statement, the FCA said:

“There has been a lot of work done by the [fusion_builder_container hundred_percent=”yes” overflow=”visible”][fusion_builder_row][fusion_builder_column type=”1_1″ background_position=”left top” background_color=”” border_size=”” border_color=”” border_style=”solid” spacing=”yes” background_image=”” background_repeat=”no-repeat” padding=”” margin_top=”0px” margin_bottom=”0px” class=”” id=”” animation_type=”” animation_speed=”0.3″ animation_direction=”left” hide_on_mobile=”no” center_content=”no” min_height=”none”][Claims Management Regulator (CMR)] to drive up standards and it is important that this continues in the interim period. We will work closely with the government and the CMR to ensure that there is a smooth handover of regulation to us.”

The Government had already announced in February 2016 a series of restrictions on the fees CMCs can charge. The proposals include limiting fees to 25% of the compensation and at £300 for all claims worth more than £2,000. Taking fees before the CMC has done any work, and taking an upfront fee where the lead is referred to another company would also be banned.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.
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A series of measures aimed at encouraging savings were announced by the Chancellor of the Exchequer, George Osborne MP, in the 2016 Budget speech.

The headline ISA limit will rise from the current level of £15,240 to £20,000 in the 2017/18 tax year.

A new lifetime ISA was also announced, which will allow investment in both cash and stocks & shares, and which will allow planholders the option of using the funds to purchase a home or to save for retirement. Once these new ISAs become available in April 2017, they will be available to those aged between 18 and 39 when the plan is taken out. Contributions of up to £4,000 per tax year can be made, and the Government will top up these contributions by 25%. Contributions can be made up until age 50. If the funds are withdrawn before age 60, and not used to buy a home, then the planholder will forfeit the Government bonus and need to pay an exit penalty.

No changes were made to the system of pension tax relief. Some commentators suggested that the lifetime ISA could discourage employees from joining their workplace pension schemes.

Firms could find that some of their clients have more disposable income. The income tax personal allowance will rise to £11,500 in 2017/18 (it will be £11,000 in 2016/17), and the higher rate tax threshold will rise to £45,000 in 2017/18 from the current level of £42,385.

The self-employed will no longer need to pay class 2 National Insurance contributions from 2018.

Firms’ clients who receive additional income can benefit from two new allowances of £1,000 each. The first covers rental activities – renting out rooms, driveways, storage space etc. at home; and the other covers ‘occasional jobs’, which includes not only casual labour such as babysitting, but also online trading activities. Individuals will no longer have to declare the first £1,000 of income from each of these two areas.

Small business clients will be cheered by news that the threshold for small business rate relief is to rise from the current £6,000 to £15,000 from April 2017. Hence companies will not need to pay any business rates if their property has a rateable value of £15,000 or less. Higher rate relief will increase from the current £18,000 to £51,000.

Larger corporate clients may welcome the news that corporation tax is to fall to 17% by 2020, but may be less keen on the restrictions announced on using debt interest payments and carried forward losses in order to reduce the corporation tax bill.

Insurance Premium Tax, paid by insurers on motor and household insurance, will rise by 0.5% to 10%, having already been raised by 3.5% in the Budget 12 months earlier. Firms inevitably pass on these rises to customers.

Capital Gains Tax will reduce to 10% for basic rate taxpayers and 20% for higher rate taxpayers, effective for the 2016/17 tax year, except where a second home or buy-to-let property is sold, in which case the rates remain at 18% and 28%.

Advisers may also be cheered by the news that the Money Advice Service (MAS) is to be scrapped. The Pensions Advisory Service and Pension Wise will be combined into a new pensions guidance body, while the MAS will be replaced by what is described as a ‘slimmed down money guidance body’. The wording of the announcement may suggest firms’ levies to fund the new organisations will be lower, although exact details are not yet available.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

The Financial Advice Market Review (FAMR) has made 28 recommendations for changes to the financial services marketplace. The primary aim of the review, jointly conducted by HM Treasury and the Financial Conduct Authority (FCA), is to improve public access to financial services, amid concerns that advice is too expensive for some consumers, or that others do not see the benefits of advice or are unsure about how to go about finding an adviser.

The Review recommendations include:

• The Treasury should launch a consultation on a proposal to amend the definition of regulated advice, so that a firm’s actions are only considered to be regulated advice when a personal recommendation is made
• The FCA should issue guidance to firms on how they can offer ‘streamlined advice’ and still meet regulatory requirements, guidance which should include a series of illustrative case studies. Firms have previously suggested they could limit the costs of giving advice if they were able to carry out ‘simplified advice’ focussed on a single need area, but have been wary of how the regulator and the Financial Ombudsman Service (FOS) might view the matter
• Trainee advisers to be allowed to give advice under supervision for four years, up from the existing two and a half years, before being required to pass an appropriate Diploma qualification
• The FCA should work with the industry to look at reducing the length of suitability reports
• The FCA should set up an Advice Unit aimed at assisting firms in launching automated advice (or robo-advice) systems
• The Treasury should consider allowing consumers to access a small percentage of their pension fund before the usual age of 55 in order to pay for regulated advice on retirement planning
• The Financial Services Compensation Scheme (FSCS) should look at introducing risk-based levies based on individual products, and on reforming the existing funding classes
• The FCA should review availability of professional indemnity insurance for smaller firms
• The FOS should conduct ‘Best Practice’ discussions with firms and trade associations, where cases of interest can be discussed and best practice going forward can be agreed
• The FOS should consider providing additional guidance for firms via its website

Contrary to media speculation, the FAMR has not proposed allowing simple investment advice to be given without a Level 4 qualification, or suggested a return to commission for investment advice, or proposed a long stop – an over-riding limit regarding how long after the advice is given that a complaint can be made.

Firms should note that these are recommendations only at present, and that the rules have not yet changed.

Tracey McDermott, the FCA’s acting chief executive and joint chair of the Review, said:
“The package of reforms we have laid out today will help increase both the accessibility and affordability of the advice and guidance, to ensure that consumers get the help they really need when they really need it.”

Chris Hannant, Director General of the trade association the Association of Professional Financial Advisers, said:

“We welcome and support the review’s analysis of the problem of ensuring more widespread access to financial advice. However, more could be done and the conclusions represent a missed opportunity. While many of the proposals will be helpful, concrete measures beyond further clarification and guidance are needed. In that sense, the review of FSCS funding is a substantive and positive step in the right direction.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

The Financial Conduct Authority (FCA) is to conduct a pilot scheme in summer 2016 where it will publish information on its website regarding whether insurers reject or uphold insurance claims.

The information will be published for critical illness, income protection (permanent health) and private medical insurance policies. The following data will be published:

• How often policyholders make a claim
• The proportion of claims upheld
• The size of the average payout

Christopher Woolard, director of strategy and competition at the FCA, said the initiative would have a positive effect on insurance companies, “encouraging them to focus on improving the value and performance of their products, whilst giving stakeholders and consumers more insight into the value they offer”.

Roy McLoughlin, IFA at London-based firm Master Adviser, said that the publication of the data could boost consumer confidence in the insurance industry. He said that making the data public was “essential if an adviser is to have faith in delivering the message that polices do pay out”.

He added:

“Remember that research tells us that the distrust the public has is still at an unacceptable level. We do not desire league tables. However if we don’t deliver this evidence then the consequences will be fatal as the consumer and adviser faith in these essential products will diminish.”

The data may be used as another way for financial advisers to compare different insurance providers. Any adviser who has access to a range of insurers would be expected to include premium-based research in their client files. However, it is not automatically expected that advisers recommend the cheapest product in every case, although each file should justify why a particular insurer was chosen.

Factors, other than initial price, an adviser can use when comparing insurance products include:

• The range of illnesses covered
• The definitions used for various illnesses, e.g. is a successful claim likely on diagnosis of cancer or heart disease, or only when the disease has reached an advanced stage?
• The criteria for assessing claims, e.g. are income protection claims based on the individual’s ability to carry out their regular occupation, to carry out any occupation or to carry out a number of specified physical tasks?
• The availability or otherwise of premium reductions if the policyholder can demonstrate they lead a healthy lifestyle
• Whether the premium and/or benefits are fixed or will rise each year
• Whether the premium and/or benefit level is fixed throughout the policy term, or is subject to review by the insurer
• The customer service standards of the insurer

However, if using a provider’s claims record as a justification, advisers must remember that past data is not necessarily a guide to the future – a similar caveat to the once that applies when using investment performance data as a justification for recommending a particular investment option.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

Stockport-based debt management firm PDHL Ltd has been stripped of its interim permission by the Financial Conduct Authority (FCA), and had its application for full permission refused. The media are describing PDHL as the largest firm to date in the consumer credit sector to be refused authorisation by the regulator.

The main issues of concern to the FCA were the suitability of advice given by the firm; and its level of human resources, both in terms of the number of debt advisers employed and the expertise available at Board level. These deficiencies were identified even though PDHL has been conducting debt management activity under the auspices of the Office of Fair Trading since 2007.

In July 2015, the FCA forced PDHL to stop accepting new business, but did not give its reasons for the decision at the time.

Regarding suitability of advice, a high proportion of customer files reviewed by the FCA did not show that the advice was tailored to individual circumstances, that all relevant options had been considered, that a full income and expenditure analysis had been carried out or that the risks associated with particular debt solutions were explained.

As an example of the standard of PDHL’s debt advice, the regulator cites the example of a customer who informed the firm that he had lost his job, yet it was two months before his case was reviewed, and no revised payment plan was ever agreed. Another customer continued to pay the firm £30 per month under his plan even though the adviser was aware he was borrowing from his mother to do this.

It was also of great concern to the FCA that the firm’s advisers appeared to be unable to identify vulnerable customers.

The firm admitted that it needed 30 debt advisers to adequately service its customer base, however it had only 14 advisers assessed as competent and only two who were able to properly deal with vulnerable customers.

The firm’s board were not considering sufficient management information to allow them to identify and mitigate regulatory risks. The Managing Director, Head of Customer Services, Risk Manager and Compliance Director all left the firm within a short period of time.

In summary, the FCA says it cannot be confident that PDHL could satisfy threshold condition 2D (Appropriate resources) and threshold condition 2E (Suitability).

PDHL initially appealed to the Upper Tribunal, but has now withdrawn this appeal and has accepted the FCA’s findings. The FCA Final Notice refers to a number of areas in which the firm admitted its arrangements were inadequate.

As it does whenever it decides not to authorise a firm that previously held interim permission, the FCA is now writing to the firm’s 16,000 customers advising them that the firm is no longer authorised and informing them of sources of free debt advice.

Jonathan Davidson, director of supervision – retail and authorisations, at the FCA, said:

“Poor debt advice can lead to consumers trying to make payments on their debt that they cannot afford which is particularly serious for those in vulnerable circumstances and why we have paid very close attention to the advice given to consumers by debt management firms.
“As part of our authorisation process, all firms must demonstrate that they have customers’ interests at the heart of their business.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

A recent judgement from the Financial Ombudsman Service (FOS) has highlighted the importance of financial advisers reviewing a client’s entire portfolio on each occasion they advise them.

In a recent judgement, Perspective Financial Management Ltd has in effect been held liable for advice given to a client by a previous adviser. The client was initially advised by her first adviser, who is not named, to invest some of her pension fund into a very high risk Unregulated Collective Investment Scheme (UCIS). When she switched adviser to Chambers & Co (Chelmsford) Ltd a year later, that firm’s adviser recommended she top up her investment in the UCIS.

When the client made a complaint to Chambers, an FOS adjudicator found in her favour, as the second adviser should have considered whether the initial investment was suitable before making a recommendation to top-up. Ombudsman Lesley Stead agreed with the adjudicator’s decision when Chambers’ principal firm, Perspective Financial Management Ltd, appealed against the initial findings. As the authorised entity, Perspective will now have to compensate the client.

The FOS has ordered Perspective to pay compensation to the client based on the growth her pension fund would have achieved if half had been invested in the FTSE WMA Stock Market Income Total Return index, and the other half in a fixed-rate bond. Interest at 8% will then need to be added to this amount, and the firm will also need to pay an additional £200 for distress and inconvenience.

Ms Stead commented:

“I agree with the adjudicator, that in giving advice about the investments in 2010, the adviser should have reviewed the existing portfolio. On doing so, existing investments in the fund should have been identified as unsuitable and too high risk.

“And the adviser ought to have recommended the sale of those holdings in the fund, which was liquid at that time. The adviser didn’t do that, and instead compounded Mrs B’s position by advising that she invest more in the fund – effectively endorsing the earlier advice.”

If a client has signed up to an ongoing review service, then the adviser must ensure that they deliver the promised level of ongoing service, and at the times specified in the service agreement document. Typically, an ongoing advice service will include a review of a client’s risk profile and asset allocation on at least an annual basis.

Assessing attitude to risk is a vital part of any financial review. If it is identified that a client’s existing portfolio is too risky, then they should be advised to switch to lower risk investments.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

Information supplied by consumer advice organisation Citizens Advice (CitA) has highlighted the importance of advisers communicating to their clients in plain English.

CitA has released details of its experiences when delivering the free Pension Wise guidance service. It says that the pension language consumers most frequently fail to understand are:

• Open market option – the right to shop around for the best annuity available in the marketplace, rather than simply accepting the quote offered by the pension provider
• Safeguarded benefits – such as a guaranteed minimum pension, or a guaranteed annuity rate
• Uncrystallised funds pension lump sum – a cash withdrawal from a pension fund without entering into a formal product such as an annuity or a drawdown plan

CitA also commented that large numbers of consumers do not understand that they can access their pension savings at any time after the age of 55, and instead believe that they have to select their retirement date in advance and stick to this.

Other jargon CitA says consumers have difficulty understanding include:

• Flexi-Access Drawdown – the client enters into a policy under which they can access as much or as little of their pension fund as they wish as income and/or lump sums. Meanwhile, the remaining monies remain invested, and hopefully continue to grow
• Lifetime Allowance – a limit on the sum that can be withdrawn from an individual’s pension schemes without giving rise to a tax charge. The allowance applies to the combined value of all of an individual’s pension savings, other than the state pension. From April 2016, the Lifetime Allowance will reduce from £1.25 million to £1 million
• Benefit Crystallisation Event (BCE) – an event that means the value of an individual’s pension savings will be assessed to see if they exceed the Lifetime Allowance. BCEs include purchasing an annuity or drawdown product, dying before accessing the pension pot or not accessing pension funds by age 75

Gillian Guy, chief executive of CitA, commented:

“Pensions can feel like a foreign language for many people.

“Tricky terms like flexi-access drawdown and uncrystallised funds pension lump sum are mystifying consumers, but our staff at Citizens Advice also find people misinterpreting seemingly more straightforward pensions terms.

“A small misunderstanding about your pension can lead to a lot of confusion, and mean some consumers don’t get the best option for them.
“If the pensions industry took the simple step of getting rid of complex language, it would go a long way to help people get on the right track towards a more financially secure retirement.”

The Financial Conduct Authority’s rules say that a client communication should be “presented in a way that is likely to be understood by, the average member of the group to whom it is directed.” Advisory firms must ensure that where jargon is used on their promotions and suitability reports that these terms are also explained in plain English. Terms should also be expressed in full, instead of using abbreviations such as FAD, BCE and UFPLS.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

Consumer financial website Moneysavingexpert.com has responded to the Financial Conduct Authority (FCA) consultation on payment protection insurance (PPI), and has referred to the regulator’s proposals as “a gross injustice”.

The FCA has been consulting on two proposals:

• A deadline, sometime in 2018, after which PPI mis-selling complaints will not be considered
• A requirement for firms to pay compensation to consumers who complain about undisclosed commission on PPI contracts, and where this commission amount exceeded 50% of the premium. This follows a recent court judgement, known as the ‘Plevin case’

In his executive summary to his firm’s response, Moneysavingexpert.com founder Martin Lewis called the deadline (or time-bar) “an anti-consumer move.” He cited the fact that many firms still have large numbers of PPI complaints upheld by the Financial Ombudsman Service – which effectively means that the firm incorrectly rejected the complaint originally – and suggested that only firms with an FOS uphold rate of below 20% should benefit from the deadline.

Mr Lewis also remarked on the apparent contradiction between suggesting a PPI deadline at the same time as paving the way for a new wave of complaints as a result of the Plevin judgement. Regarding commission-related complaints, he commented:

“Against all natural justice the FCA plans to put a time-bar on this too, even before it’s started. This is plainly ridiculous and even if a time-bar is imposed Plevin cases should not be covered by it.”

He then suggested that the deadline would be introduced anyway, regardless of his views, and turned his attention to ensuring that every consumer was made aware of the fact their right to complain was to be removed. Mr Lewis commented:

“However, as it is well known this consultation is a farce in terms of the time-bar – it is going to happen anyway – we also need to address the way to limit the damage of this move.”

The 18 firms that sold the most PPI policies have been informed that they will need to fund an advertising campaign alerting people to the deadline. Mr Lewis called for this campaign to go further, by saying:

“For a time-bar to work, every single person who has had PPI must be written to by their bank to inform them of the details.”

The best chance of seeing the deadline scrapped may lie with a legal challenge being mounted by claims management company We Fight Any Claim. The company has received legal opinion that the deadline contravenes the FCA’s statutory objective to protect consumers.

Supporters of the deadline cite the fact that, by 2018, ten years will have passed since most of the mis-selling occurred, and that this length of time should be sufficient for a consumer to make a complaint. Having to set aside massive sums for PPI compensation has also delayed the return to profitability of some leading banks, and in some cases has extended the period of time for which they have been in state ownership. In late February 2016, Royal Bank of Scotland (RBS) declared a loss of £2 billion, and announced it had been forced to increase its PPI compensation reserve to £4.3 billion, of which £3.3 billion has already been paid. RBS is still 73% owned by the Government.

The FCA’s PPI consultation has now closed.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.