Three significant events have occurred within the PPI industry since July 2009:
- The Competition Commission’s draft Order
- The FSA’s Consultation Paper: CP09/23
- Agreed measures relating to Premium Variation Clauses on
MPPI contracts
Looking forward, there will be significant changes in the way that PPI is marketed, sold and regulated.
- Prohibition on selling PPI at the point of sale of credit*
- Provision of a personal quotation to the customer
- Changes to the content of marketing material
- Annual PPI statements to be issued to customers
- Commission of independent mystery shopping
- Requirement to provide compliance reports
Looking back, there is a significant retrospective challenge for businesses:
- New guidance on the review of PPI complaints (excluding MPPI)
- Requirement to review all rejected PPI complaints (excluding
MPPI) since 14th January 2005 within 12 months of the Order
being made
- Changes to redress which includes (where appropriate) a
restructuring of the loan as if the PPI had not been sold
- Review of policy variation and cancellation clauses on MPPI
contracts
- Freeze premiums and cover for existing MPPI customers for at
least the remainder of this year
- Proactively refund increases in premiums, and reverse reductions
in cover, for MPPI customers who have experienced changes to
their policy in 2009
- Reinstate policies where a customer had cancelled their MPPI
within two months of an increase in premium or reduction in
cover made during 2009
* This may now change after the Competition Appeal Tribunal decided to uphold Barclays’ appeal
against this point on 16/10/2009
PPI. What do Momenta offer?
Advisory: Momenta can work with you to interpret the new requirements and understand their impact on your products, processes and procedures
Marketing Materials: Our outsourced Financial Promotions Studio can provide an independent review of your sales literature in line with the clarity of marketing material requirement
Training: Momenta has significant experience in the design and delivery of training in Sales Regulation. We are also experts in training assessment and validation of learning
Mystery Shopping: Momenta’s outsourced Mystery Shopping service will supply you with a thorough and independent assessment of your selling practices
Resourcing: Momenta can supply you with people to help with any contract review or retrospective complaint handling project
Our Proposition:
Whatever the requirement, our clients have access to:-
Scale: we can supply one person, or one hundred people!
Agility: we will work with you to understand your precise requirements
and respond quickly
Competence: our associate bank is subject to rigorous quality control to ensure our clients are provided with quality people quickly
Management: we will set in place a transparent reporting process so that you know at any time where we are against milestones
Range: we can supply people to deal with simple and complex cases, throughout the UK and the Republic of Ireland
Personal touch: you will have a dedicated relationship manager to work with you to ensure the success of any project
Value: our competitive pricing takes into account the number of people required and their skills |