FCA director speaks on pensions and other inter-generational challenges

It is not normal for a speaker to quote 1980s pop supergroup Mike and the Mechanics in a speech on financial issues! However, Christopher Woolard, Executive Director of Strategy and Competition at the Financial Conduct Authority (FCA) opened his July 2018 speech at the Pensions Policy Institute in London with the line:

“Every generation blames the one before. And all of their frustrations, come beating on your door.”

Mr Woolard explained that the lyrics could have relevance to:

  • The frustrations of young people trying to get on the housing ladder
  • The attempts of those in their 50s to put aside enough to enjoy a comfortable retirement
  • The worries of those in their 80s about their health, or about leaving a legacy for their children

The speaker then quoted the oft-repeated line “it wasn’t like that in my day”, and suggested that such a statement was often true, noting that the proportion of 25 to 34 year-olds who own their own home has declined from 67% in 1991 to 36% in 2014, while the proportion using the ‘Bank of Mum and Dad’ for help in buying a home has risen from one fifth to one third in just eight years.

1.42 million people currently aged 35 to 64 will still be paying off their mortgage in retirement.

Mr Woolard then commented on the pensions issues facing a slightly older group of people, commenting that 20% of those aged 45 to 54 have no form of private pension, and that for almost 50% of those reaching retirement the state pension would be their main source of income.

The FCA director then quoted some statistics to demonstrate that many of today’s older generation are asset rich but cash poor. 50% of 70-year olds have assets of approximately £220,000, while 25% have total wealth of around £450,000. However, one quarter of those aged 70 to 89 receive a net income of £8,300 or less, equivalent to the new state pension level.

Mr Woolard added that even if the older generation have significant assets, they still face losing these to pay for long-term care.

He suggested that the generation who are best off could be the three million people aged 65 to 75 who receive income from final salary pensions, who own their home outright and have median wealth of £460,000.

The FCA director suggested that his organisation could alleviate inter-generational issues in three main ways:

  • Ensuring consumers are engaged when making decisions
  • Making sure firms design products that offer good value for money
  • Encouraging consumers to invest and save in appropriate areas

In support of the last of these, he made reference to the recently published pension proposals. The FCA is concerned that a third of consumers who enter drawdown without taking advice have their entire holding in cash, when research shows that they could increase retirement income by up to 37% by investing in a mix of assets instead. The proposals to address these issues include a requirement for providers to send ‘wake up’ packs every five years, and to provide clearer information once an individual customer has started accessing their retirement savings.

In conclusion, Mr Woolard stated that the FCA will publish a paper on intergenerational issues later in 2018.

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


FCA confirms near final rules for SMCR

The Financial Conduct Authority (FCA) has published a series of papers explaining how it plans to implement the Senior Managers & Certification Regime across all sectors of the financial services industry.

At present the Regime only applies in the banking sector, but it will apply to all FCA-authorised firms from December 9 2019.

The Regime has three main components:

  • The Senior Managers Regime
  • The Certification Regime
  • The Conduct Rules

The Senior Managers Regime will encompass individuals carrying out the following roles:

  • SMF1 – Chief Executive
  • SMF3 – Executive Director
  • SMF27 – Partner
  • SMF9 – Chair
  • SMF16 – Compliance Oversight
  • SMF17 – Money Laundering Reporting Officer (MLRO)

It will cover individuals whose activities are equivalent to that of a chief executive, director etc. even if they do not actually have this wording in their job title.

Firms will be required to draw up a ‘statement of responsibilities’ for each of the individuals listed above, which should set out exactly what each person is responsible for. It is possible for the same person to carry out more than one of these roles, indeed this may be necessary in some smaller firms. The FCA will be able to take enforcement action against the relevant Senior Manager if there are regulatory failings in their personal area of responsibility.

Each Senior Manager’s Duty of Responsibility will mean that the FCA can take action against them where all of the following apply:

  • There was misconduct by the Senior Manager’s firm
  • At the time of the misconduct, the Senior Manager was responsible for the management of any of the firm’s activities in relation to which the misconduct occurred
  • The Senior Manager did not take steps that they could reasonably have been expected to take to prevent the misconduct occurring or continuing

Essentially, this system replaces the existing FCA Approved Persons Regime. Senior Managers will need to be approved by the FCA prior to commencing their roles, but once approved by the regulator, it will be the firm’s responsibility to carry out an annual assessment of whether the individual is ‘fit and proper’ to continue in such an important role.

The Certification Regime applies to individuals within the firm who are not Senior Managers, but who still hold positions of responsibility, especially if their actions could have a significant impact on whether the firm’s customers are treated fairly. There is no need for individuals in Certification roles to be approved by the FCA, however firms are still required to carry out their own annual fit and proper assessments.

Suggested examples of staff who might be covered by the Certification Regime include:

  • Head of HR
  • Head of Complaints Handling
  • Head of Product Design
  • Non‑SMF Partners

The FCA suggests that a fit and proper assessment of a Senior Manager, or of a person in a Certification role, might include:

  • Criminal records checks
  • Obtaining regulatory references

An assessment of fitness and propriety must consider the individual’s honesty, integrity and reputation; competence and capability; and financial soundness.

The Conduct Rules could be said to be something of a ‘Hippocratic Oath’ for the financial services industry. These Rules will require staff at all levels to:

  • Act with integrity
  • Act with due care, skill and diligence
  • Be open and co-operative with the FCA, PRA and other regulators
  • Pay due regard to the interests of customers and treat them fairly
  • Observe proper standards of market conduct

Once the Regime is in force, the existing Financial Services Register will only list the Senior Managers at each firm. This means that many firms will have fewer listed individuals than is the case at present. The FCA is therefore planning to introduce a new Directory to complement the Register and proposes that all Senior Managers and holders of Certification roles will be listed in a firm’s entry on the Directory.

Firms recommended to make steps to prepare for the new Regime.

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



Citizens Advice highlights benefits of a rent to own cap

A cost cap on rent-to-own products is likely to come into force by April 2019, and national charity Citizens Advice has calculated that the cap could save consumers an average of £276 per product. Across the board it believes total cost savings of £62 million could be achieved.

The charity also found that found 25% of people who had purchased a product via rent-to-own were unaware the total amount they would have to repay.

Gillian Guy, Chief Executive of Citizens Advice, said:

“By 1 April 2019, it will have been 853 days since the FCA launched its high-cost credit review. Until a cap is introduced, consumers will continue to pay over the odds for these high-interest products.

“Caps can work, we’ve seen this with payday loans where thousands of consumers have been protected by the FCA and are now better off as a result.

“The FCA has recognised the massive harm caused by the high interest rates on tempting rent-to-own deals. It should now stick to its own deadline to implement a cap. No one should have to pay more than double what they borrow.”

The Financial Conduct Authority (FCA) unveiled a variety of new proposals relating to various parts of the high-cost credit sector in June 2018. The consultation on these plans ends on August 31 2018.

Regarding rent-to-own, the proposals include:

  • Banning firms from selling extended warranties at point of sale
  • Considering a formal price cap on rent-to-own prices

At this stage, the FCA has not confirmed that a price cap will definitely be introduced, nor has it given details of the level of any cap. However, it does say that changes could be introduced in the rent-to-own market by April 2019.

The regulator notes that rent-to-own costs can be very high, and that it has seen examples of consumers needing to pay more than five times the amount that the same goods would cost if bought on the high street.

Citizens Advice’s response to the consultation has proposed a 100% cost cap on rent-to-own goods, and a limit of £15 on late payment fees.

The FCA has taken action against three large rent-to-own firms in recent months. In the latest instance, a firm which provides household goods to customers on hire purchase agreements was required to pay refunds totalling £2.1 million to some 37,000 customers. The redress will be paid as a mixture of cash payments and balance refunds.

The FCA’s investigations identified that the firm was failing to carry out sufficiently rigorous affordability assessments before allowing customers to purchase goods on credit and was therefore providing some of its customers with loans that they could not afford to repay.

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


Call for pension withdrawal cooling off period

Calls are increasing for the Government to grant a cooling off period when a consumer accesses their pension pot without taking advice.

Stephen Lloyd, the Liberal Democrat Work and Pensions spokesman, said he was particularly concerned that people did not understand the tax implications of pension withdrawals, and that lump sum withdrawals were taxed as income, possibly drawing people into higher rate tax brackets. He has written to Secretary of State for Work and Pensions Esther McVey explaining his concerns.

Mr Lloyd said:

“The pensions freedoms have enabled many people across the country to better plan for their retirement, but the legislation was always intended to be a work in progress, the cold calling ban and this cooling off period are the next logical steps.”

Nationwide advisory firm LEBC had previously advocated a 30-day cooling off period.

In early July 2018, the Financial Conduct Authority (FCA) unveiled a series of new proposals regarding retirement income options, although these did not specifically address the issue of whether individuals were aware of the tax implications of withdrawals. The regulator did note however that 32% of those entering drawdown now do so without advice, whereas the equivalent figure prior to the introduction of the Government’s pension freedoms was just 5%. Drawdown is undoubtedly a complex area.

One of the other proposed new rules is for providers to be required to send ‘wake-up’ packs to every pension customer. The first such pack would be sent when the customer reaches age 50, and a similar pack should continue to be sent every five years until such time as they have fully accessed their retirement savings. These packs will include a one-page summary document – which will include:

  • The individual’s contribution rate
  • The fund value
  • Whether guarantees or other special features apply to the plan
  • A statement asking the individual to consider whether they are saving enough
  • A statement about the availability of pensions guidance.

A series of relevant risk warnings will also be included in the wake up pack, and firms will not be permitted to send any marketing material alongside the pack.

The FCA is also taking steps to ensure consumers are better informed at the time they choose to access their pension pots. The ‘investment pathways’ proposals would require providers to set out three investment solutions that the customer could make use of upon entering drawdown. These pathways should include one solution for each of the following three strategies:

  • Accessing the entire pension pot over a short period
  • Using the pot to provide a regular retirement income
  • Keeping the money invested, and maybe accessing it occasionally over time

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


Independent review of FOS completed – organisation cleared of bias but issues with staff knowledge identified

Former ‘Which?’ executive director Richard Lloyd has completed his independent review of the operation of the Financial Ombudsman Service (FOS). This review has found that there may be issues with the knowledge of some the Service’s investigators, however there was no evidence that the decision-making process is biased against customers.

Mr Lloyd said:

“The data shows no significant correlation between the reduction in pressure and uphold rates – in fact there was a slight reduction in uphold rates.

“This suggests that, overall, ‘target pressure’ did not incentivise caseworkers to reject cases in favour of businesses.”

On the subject of the knowledge of the FOS adjudicators, Mr Lloyd suggested this may be lacking, especially for some of the more complex products. He has called for further development of training, policies and procedure guides. He commented:

“As it adapts its casework model, based on the investigation model which relies on staff being skilled across a range of different types of cases, the Fos has recognised that where these higher risks arise, case-handlers require more support, or that the problem needs to be looked at by an experienced product expert with up to date knowledge.

“New investigators can lack knowledge, confidence and consistent exposure to complex problems, and so more often use internal helplines and product specialists for advice.”

Another criticism made of the organisation was that it has been prioritising ‘efficiency of service’ over maintaining quality standards, and Mr Lloyd has recommended that this is addressed.

Finally, the recommendations asked the relevant authorities to consider whether a new system of funding the Service may be more appropriate – one based on the risk each firm poses.

Caroline Wayman, chief ombudsman, said:

“We are grateful to Richard Lloyd for conducting such a thorough review.

“We’ll be considering carefully what it means for our service, keen to learn from the past so we can do things even better in the future. We will publish an update on our progress by the end of the year.”

Mr Lloyd and the Chief Executive and Chair of FOS will appear before the Treasury Select Committee in the week commencing July 16, where they can expect to be questioned about the review.

The review was commissioned to look at concerns raised by the Channel 4 documentary Dispatches, where an undercover reporter found evidence of staff siding with firms in disputes in order to meet their targets, and of a lack of staff training on complex products.

Quotes from FOS staff who made anonymous contributions to the undercover reporter included:

“Training was not adequate. We rushed through complicated financial issues and processes. I often didn’t know what I was doing.”

“I’m not proud to admit it but I’ve done it myself – just taken a chance and just slung stuff through, with any old decision.”

“Sometimes I’ve not even heard of the products. I have to Google what it is first.”

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


FCA chair speaks about data threats

The chair of the Financial Conduct Authority (FCA) has given a speech with the dramatic title “How can we ensure that Big Data does not make us prisoners of technology?Charles Randell was speaking at the Reuters Newsmaker event in London in early July 2018.

He began by describing how algorithms play a big part in our lives. Mr Randell said:

“An algorithm decided the results of your internet searches today. If you used Google Maps to get here, an algorithm proposed your route. Algorithms decided the news you read on your news feed and the ads you saw.

“Algorithms decide which insurance and savings products you are offered on price comparison websites. Whether your job qualifies you for a mortgage. Perhaps, whether you are interviewed for your job in the first place.”

The FCA chair added that some people have questioned whether we still live in a truly democratic society, given the influence that algorithms have.

In support of this argument, he made three points:

  • Big Data – there are now “enormous and detailed datasets about many different aspects of our lives.”
  • Artificial intelligence and machine learning – these Big Data can be mined and analysed more extensively than ever before. Firms can predict our future behaviour, and use the results of data mining to decide whether to offer us products and services, and on what terms
  • Behavioural science – as firms understand more and more about human behaviour, they can target their marketing efforts accordingly

Next, Mr Randell went as far as to question whether the reach of Big Data was so large that the existing regulatory system was becoming inadequate, as he commented:

“The power of Big Data corporations and their central place in providing services that are now essential in our everyday lives raise significant questions about the adequacy of global frameworks for competition and regulation. The ordinary consumer may in practice have no choice in whether to deal with these corporations on terms which are non-negotiable and are often too general to be well understood. And without access to the data which consumers have signed – or clicked – away, new businesses may find it very difficult to compete.”

He cited two examples of what might be considered less ethical ways in which firms had used data: increasing the car insurance quotes on price comparison sites if the individual had a name that suggested they were from an ethnic minority; or cutting cardholders’ credit limits when charges began to appear for marriage guidance counselling.

Then Mr Randell highlighted that it was people who designed technological innovations, and that on occasions these people may need to be held accountable, by saying:

“People, not machines, need to understand and control the outcomes that the technology they are designing is producing; people, not machines, have to make the judgement as to whether these outcomes are ethically acceptable – and ensure that they don’t just automate and intensify unacceptable human biases that created the data of the past. A strong focus on checking outcomes will be essential as some forms of machine learning, such as neural networks, may produce results through processes which cannot be fully replicated and explained.”

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


Adviser trade body suggests firms can’t cope with volume of regulatory changes

One of the largest trade associations representing financial advisors has suggested that the pace of regulatory change in recent months has been so great that authorised firms have been unable to keep up with the ever-shifting landscape.

The Personal Investment Management and Financial Advice Association (PIMFA) made its comments in a consultation response to the Financial Conduct Authority (FCA) Mission document.

In the response, PIMFA says that:

“The volume of regulatory changes over the past year or so is unprecedented and firms, particularly smaller firms, are unable to digest and action all the rule changes.”

In support of its argument, the Association cited the lack of support provided to Article 3 firms regarding the Markets in Financial Instruments Directive Part II (MiFID II). It claimed that website guidance on this topic was only posted by the regulator some six days after the Directive had come into force.

The Association calls on the FCA to do more to help firms, by commenting:

“The vast majority of firms want to comply with the rules but they do not wish to spend hours trying to figure out what they should do.

“FCA need to review, in conjunction with other stakeholders, their communication with firms including the content of the website to ensure firms are readily able to understand their regulatory obligations and FCA supervisory expectations.”

The pace of change can be rapid at times, and perhaps it illustrates the importance of engaging an expert compliance consultant who can provide re-assurance and guidance.

PIMFA’s response also comments on how the FCA’s Board determines the effectiveness of the regulator’s supervisory approach? It asks whether the fact that there have been “massive claims on the Financial Services Compensation Scheme” indicates that there have been failures in that supervisory approach.

The FCA says that its ‘Mission’ is “designed to provide a guiding set of principles around the strategic choices the FCA makes. It will inform the FCA’s strategy and day-to-day work over the coming years.”

The key themes of the Mission are:

  • What level of consumer protection should a regulator provide?
  • Should protection of vulnerable consumers be a priority, and if so what steps should the FCA take to achieve this?
  • To what extent should the FCA get involved in consumer redress schemes? How should it decide what redress is paid, to whom, and when; and how should it communicate with consumers regarding these schemes?
  • How does the FCA identify wrongdoing within firms, how does it decide what action to take against offending firms and how can it better explain what action it is taking and why?
  • In what circumstances can the FCA take action against firms?
  • How does the role of the regulator tie in with government policy?
  • Is the FCA making appropriate use of its powers relating to competition, supervision and enforcement?
  • How could the FCA Handbook be improved?

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



FCA issues paper on firms’ operational resilience

In conjunction with the Bank of England and the Prudential Regulation Authority, the Financial Conduct Authority (FCA) has issued a discussion paper on the “operational resilience” of authorised firms.

In launching the paper, the FCA notes that:

“The challenges for operational resilience have become even more demanding given a hostile cyber-environment and large scale technological changes. As recent disruptive events illustrate, operational resilience is a vital part of protecting the UK’s financial system, institutions and consumers.”

It calls on senior management to have an “increased focus on setting, monitoring and testing specific impact tolerances for key business services.”

The paper classifies the challenges to building operational resilience into five categories:

  • Technological innovation – including advances in fintech, artificial intelligence, distributed ledger and crypto assets
  • Changing behaviours – such as a demand for instant access to financial services, faster transactions and advances in mobile technology
  • Keeping pace – where issues include skills gaps and obsolescence
  • The “challenging environment”, which encompasses the threat of cyberattacks and cost pressures
  • System complexity – including issues relating to use of third parties, cross-border dependencies and concentration risk

The paper suggests that firms should have the following arrangements in place:

  • A clear understanding of what their most important business services are
  • A comprehensive understanding of the systems and processes that support these business services
  • Knowledge of how the failure of any one of these systems or process could affect the provision of the business service
  • Tested business continuity plans that would enable them to continue business services when incidents occur, or at the very least to resume business services with minimal delay
  • Clearly identified plans for who is responsible for what in the event of a disruptive incident
  • Comprehensive external communication plans which will keep customers, other market participants and the supervisory authorities clearly informed in the event of an incident

An ‘incident’ here could mean a cyberattack, major data loss, fire, flood, theft, anything restricting access to the firm’s premises, and a number of other seriously disruptive events – indeed it could mean anything which prevents the firm from conducting business in the usual way. Firms of all sizes, across all business sectors, should ask themselves whether they have the above arrangements in place. The paper acknowledges that even the very smallest firms are likely to have important business services.

The paper contains an extract from the June 2018 Financial Stability Report issued by the Financial Policy Committee, the body responsible for identifying systemic risks within financial services. This extract emphasises:

“Firms have primary responsibility for their ability to resist and recover from cyber incidents. The supervisory authorities expect boards to take responsibility for the cyber resilience of their firms.”

In conclusion, the paper suggests there are four key elements for firms to consider:

  • Preparation – firms should identify and focus on the continuity of their most important business services
  • Recovery – firms should assume disruptions will occur and develop the capability to adapt their business processes and practices in the event of disruptions to ensure continuity of service provision
  • Communications – firms should have strategies for communicating with their internal and external stakeholders (staff, customers, suppliers, service providers, regulatory authorities etc.) in the event of any incident
  • Governance – as in so many other areas, senior management have the primary responsibility when it comes to ensuring operational resilience

Responses to the discussion paper are invited up to and including October 5 2018.

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


Consultation on debt breathing space concludes – responses published

The Government has published a summary of the responses received to its ‘call for evidence on the proposed ‘debt breathing space’ laws.

The proposals were contained in the 2017 Conservative manifesto and would give anyone who finds themselves in serious problem debt the right to legal protections from their creditors for up to six weeks. The intention is that, during this six-week period, they could receive debt advice and enter into a sustainable debt solution.

The summary notes that under Financial Conduct Authority (FCA) rules firms should only lend money where there is a reasonable expectation that the borrower can afford the required repayments. It also notes that the FCA has a high-level principle requiring firms to treat their customers fairly.

Some of the responses to the call for evidence include:

  • Many people felt that it should be necessary for an individual to seek debt advice before being granted breathing space, while others questioned if this was appropriate for certain customers, such as those with mental health issues. Most felt it would be necessary for the individual to continue to engage with their debt adviser during the breathing space period
  • Some respondents felt it was important that there were defined characteristics to determine eligibility for a breathing space, so as to reduce the potential for abuse of the scheme
  • Most thought there should be restrictions on whether individuals could enter into a breathing space more than once over a short time span
  • Most believed that a breathing space period should be terminated early if an appropriate solution was identified
  • Opinion was divided over which debts could be included in the scheme, or whether interest and charges should be frozen during the six-month period
  • Most respondents believed that the fact someone had entered a breathing space should be registered on their credit file

The Government now intends to table the regulations enabling the breathing space scheme during the course of 2019. Prior to that, it will issue a policy proposal for consultation later this summer.

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


Court awards claimants all of their PPI commission as compensation, as FCA issues new consultation on Plevin cases

Whilst it is not introducing any new rules, the Financial Conduct Authority (FCA) is proposing new guidance on how firms should handle payment protection insurance (PPI) complaints that relate to commission on regular premium plans.

The Plevin judgement forced firms to refund commission payments to PPI customers if that commission amount exceeded 50% of the premium, and if the commission amount had also not been disclosed at point-of-sale.

The FCA is now suggesting that firms should assess not only whether they may have failed to disclose commission at the point of sale, but also whether they reminded the customer of the existence of these commission payments on an ongoing basis throughout the course of the policy.

The consultation closes on September 4. If the FCA decides to issue new guidance, it will do so in late autumn of 2018, and firms will be expected to implement that guidance immediately.

The FCA has made it clear that anyone who has had a complaint about regular premium PPI rejected will be able to make a new complaint based on this guidance.

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

“This consultation provides guidance on how to ensure fair and consistent outcomes for regular premium PPI complaints. It supports our aim of bringing the PPI issue to an orderly conclusion in a way that secures appropriate protection for consumers and enhances the integrity of the UK financial system.”

Although the FCA has issued new guidance, the deadline for making a PPI complaint remains little more than a year away.

The new proposed guidance was unveiled by the FCA just days after a court decided to award a couple a refund of their entire PPI commission. The FCA responded to the Plevin judgement of 2014 by instructing firms to refund the proportion of the commission that exceeded 50% of the premium, so if the commission was equivalent to 60% of the premium, the consumer would only receive 10%.

However, a judge at Manchester County Court has ordered lender Paragon Personal Finance to refund the entire commission amount on a PPI policy taken out by Christopher and Joanne Doran, not just the amount that exceeds 50%. In doing so, the court has decided that the existence of such a large undisclosed commission payment created an unfair relationship under contract law. In this instance, the commission was equivalent to 76% of the premium.

The FCA has said that it will not be issuing new guidance in light of the judgement, and the Manchester court ruling is not binding on other courts, so at present, it seems unlikely that the ‘Doran case’ will have as big an impact as the Plevin case. Industry experts had suggested that, had the FCA decided to react to the Doran judgement, it could have increased the industry’s PPI compensation bill by as much as £18 billion.

A spokesperson for Paragon said:

“We believe this decision is at odds with other cases heard recently and does not create a precedent.

“The Doran case is one of a handful of legacy cases for Paragon and we are considering our position regarding appeal.”

It should also be noted that the August 2019 deadline will apply only to cases where consumers seek resolution of PPI complaints via the Financial Ombudsman Service. Consumers will still be able to commence formal legal proceedings against PPI providers after that time.

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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