The CMA has issues directions to Paymentshield Limited for failure to send Annual Reviews to PPI customers as required under the Payment Protection Market Investigation Order 2011.
The directions require Paymentshield to undertake the following actions (identified in its internal audit dated December 2019) by 31 March 2020:
- Implement risk-based assurance for system-generated Annual Reviews;
- Perform quality assurance on Annual Review Content;
- Undertake a back book review for areas of non-compliance in its MPPI business and undertaking remediation where necessary;
- Implement a process to check any business that Paymentshield acquires for compliance as part of its integration plan;
- Consolidate all compliance policy and guidance documentation into one place and communicate this to staff; and
- Embed its approach to root cause analysis and rectification into its current reporting and governance arrangements; and
- by 31 July 2020, Paymentshield should also perform another assurance audit to check for fair customer outcomes and any IT change control risks including to any regulatory disclosures.
Paymentshield are then directed to appoint an independent body to carry out an assurance audit of the Order during the 20/21 financial year and annually.
Finally, Paymentshield are directed to provide the CMA with an Action Plan setting out, amongst other things,how it will comply with the above.