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Consumer Law Blog

Grounds for Making a PPI Complaint

by Bradley Askew 02 June 2011

You may have heard in the news recently about a decision in a court case between the major high street banks and the Financial Services Authority (FSA). This decision means that it is now possible for thousands of people who have purchased a PPI policy in the past to begin claim back their mis-sold PPI.  But the majority of these people will be unsure about what counts for the grounds on which a mis-selling claim can be made.

The FSA regulates the financial services industry by setting the rules and regulations which various types of financial businesses must follow. This has included the selling of PPI, regardless of whether or not the PPI seller engages in any other kind of regulated financial activity.

Under the Financial Services and Markets Act 2000 anyone who has suffered a loss or damage because the FSA's rules have been breached by a business, has the chance to take legal action against that business and make a compensation claim. The FSA rules on the selling of PPI are based on what a claim for mis-selling can be made.

The FSA's rules on PPI are known as ICOBS (Insurance Conduct of Business Standards) and they can be found in the FSA regulatory handbook. These rules cover all aspects of running an insurance business and marketing insurance products, but there are very few rules that focus just on the sales process. The FSA rules require all PPI sellers to act in an open and honest way and ensure that any product which they recommend is suitable for the consumer's financial circumstances and needs. Below you will find a few common examples that constitute a breach of FSA rules, and could result in a successful claim for PPI mis-selling:

  • The PPI seller added the Payment Protection Insurance to the loan or credit product without asking the consumer for their permission;
  • You had a pre-existing illness or medical condition, such as back ache or stress, and as a result you were not covered by the terms of the policy;
  • The loan or credit agreement contained PPI by default ,and the consumer was required to specifically ask for this to be removed if they didn't want it;
  • The PPI seller falsely stated that the consumer's application for a loan or other credit product would not be approved unless they purchased PPI at the same time;
  • The PPI seller did not tell the consumer they should shop around for the best deal and that they might be able to purchase the same level of protection much cheaper elsewhere;
  • The PPI seller falsely stated that the consumer could only purchase PPI at the time the loan was set up, and that they would not be able to protect their repayments at a later date;
  • The PPI seller did not ask you about any other insurance products which you had and so you ended up paying for a PPI policy which was no use to you because already had cover under your life assurance or health insurance;
  • You had been made aware by your employer that you may be made redundant at the time you purchased the policy, and the PPI seller did not explain that you would not be able to make a claim under the policy when you were made redundant;
  • The PPI seller did not kept any records of the information which they took from you during the sale process, and they have not properly documented their recommendations about the suitability of the policy and their warnings about the terms and conditions;
  • The PPI seller sold you a policy that was unsuitable for your needs and circumstances; you did not meet the policy requirements on employment status, age or medical history and so would be unable to claim the benefit of the policy if you lost your source of income;
  • The PPI seller failed to ask you about your age, state of health, medical history and employment status. Meaning that they did not have sufficient information to make an appropriate recommendation about the suitability of the policy and so is in breach of the FSA regulations;
  • The PPI seller received commission from the insurance company in return for arranging the sale, but they failed to mention this in your loan documents. Even if the PPI seller told you about this orally, if there is no written record then the commission is classed as a "secret profit" and the sale becomes invalid.

This list is not all the grounds for which as claim can be made, there are a large number of situations in which it is possible to argue that the PPI seller has breached FSA Rules. If you are concerned that you may have been treated unfairly in the way when buying a financial product, you should make a claim to find out if you are entitled to a refund.

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