FCA has published a detailed policy statement to back up the new rules on regular premium PPI complaints and recurring non-disclosure of commission. FCA stresses that one of the main purposes of its consultation and now the new rules is to ensure that customers who may have made complaints about mis-selling of PPI that were rejected have now disengaged from the issue, but in fact some, if not many, would be likely to find any new complaint upheld and redressed in the light of RND or sometimes Plevin.
FCA found it necessary to make rules placing requirements on lenders and brokers as it felt there was a limit to what it could achieve in its public awareness campaigns. By requiring lenders to write to certain regular premium PPI Plevin complainants whose complaints were rejected on the basis of not involving an unfair credit relationship or being out of jurisdiction, and requiring sellers to write to certain complainants who had had complaints rejected and did not receive the previous Plevin-related mailing, FCA thinks up to 150,000 consumers would be told they can make a new complaint, either in the light of RND or Plevin. A similar number of consumers should receive a letter now that FCA has clarified its guidance on RND.
FCA decided it would be retrospective and inappropriate to tell firms to reopen complaints, but would not to tell them to tell consumers that they can make a new complaint.
Affected firms now need to prepare and send the mailings as soon as possible, and in any event by 29 April 2019. FCA will work on a standard core text for the mailing and will discuss with firms the approach they should be taking to new and supplementary mailings.