CP15/39: Response form

Published: 26/11/2015     Last Modified: 26/11/2015

We are asking for comments on this Consultation Paper by 26 February 2016.

Please use the form below or alternatively, please send comments in writing to:

Lauren Dixon or Julian Watts
Specialist Supervision Division
Financial Conduct Authority
25 The North Colonnade
Canary Wharf
London E14 5HS

Email: cp15-39@fca.org.uk

We make all responses to formal consultation available for public inspection unless the respondent requests otherwise. We will not regard a standard confidentiality statement in an email message as a request for non-disclosure.

Despite this, we may be asked to disclose a confidential response under the Freedom of Information Act 2000. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by the Information Commissioner and the Information Rights Tribunal.

Note: You can take a printout of your response before clicking the 'Submit to FCA' button at the end of the form, but this will only print the visible text on screen, and you may have given longer answers. After submitting your response, the form will clear, but when we acknowledge receipt of your response by email, we can return to you a copy of your full submission as received. Check this box if you would like to have a copy of your submission returned:

Submission Details









as an individual
as a representative of an authorised firm
as a representative of a professional firm
other (please specify):
Q1

Do you agree with our assessment of the PPI landscape and trends, and that we should now seek to draw the PPI issue to an orderly close through the proposed deadline and proposed consumer communications campaign?

Q2

Do you agree with the proposed nature, date and scope of the proposed deadline?

Q3

Do you agree with the proposed aims of the proposed consumer communications campaign?

Q4

Do you agree with the proposed audience, channels, and cost of the proposed consumer communications campaign?

Q5

Do you agree with our proposed fee rule for allocating the costs of the proposed consumer communications campaign?

Q6

Do you agree with our rationale for proposing rules and guidance now concerning the handling of PPI complaints in light of Plevin, and that it is preferable in the circumstances that we, not the Ombudsman service, take the lead in this?

Q7

Do you agree with the scope of our proposed rules and guidance concerning the handling of PPI complaints in light of Plevin?

Q8

Do you agree with our proposed structuring of the new rules and guidance concerning Plevin as a separate ‘second step’ within our existing PPI complaint handling rules and guidance?

Q9

Do you agree with our proposed definition of ‘commission’ concerning the handling of PPI complaints in light of Plevin?

Q10

Do you agree with our proposal of a single 50% commission ‘tipping point’ at which firms should presume, for the purposes of handling PPI complaints, that the failure to disclose commission gave rise to an unfair relationship under s.140A?

Q11

Do you agree with our proposed examples of circumstances in which the presumptions might reasonably be rebutted? Are there other such circumstances which could usefully be specified as examples?

Q12

Do you agree with the key elements of our proposed approach to redress at Step 2 of our proposed rules and guidance concerning PPI complaint handling in light of Plevin?

Q13

Do you agree with our proposed approaches to the other elements of redress at Step 2? Do you perceive any particular practical or operational difficulties in our proposed approach to these elements?

Q14

Do you agree that consumers who have previously made rejected PPI complaints that did not mention undisclosed commission, and whose credit agreements fall within the scope of s.140A-B, should be able to raise this additional issue with the lender and have this assessed under our proposed new rules and guidance?

Q15

Do you agree with our proposed approach of handling McWilliam-type PPI complaints under our existing high level (non-PPI specific) complaints handling rules only?

Q16

Do you have any comments on our cost benefit analysis (in Annex 2)?

Q17

Do you agree with our initial assessment (in Annex 3) of the impacts of our various proposals on the protected groups and vulnerable consumers? Are there any other potential impacts we should consider?

Q18

Do you have any comments on our compatibility statement (in Annex 4)? In particular, do you have any comments on any issues relating to mutual societies that you believe would arise from our proposals?

  

Back to top >