The FCA has fined LBGI (Lloyds Bank General Insurance Limited, St Andrew’s Insurance Plc, Lloyds Bank Insurance Services Limited and Halifax General Insurance Services Limited) £90,688,400 for failing to ensure that language contained within millions of home insurance renewals communications was clear, fair and not misleading.
Between January 2009 and November 2017, LBGI sent c.9m renewal communications to home insurance customers which included language to the effect that they were receiving a ‘competitive price’ on renewal. However, LBGI did not substantiate the ‘competitive price’ language by taking steps to check that it was accurate. In 2009, LBGI rewrote its renewal communications and began to remove the ‘competitive price’ wording but the language remained in a substantial number of renewals communications throughout the relevant period despite repeated missed opportunities to address it.
Separately, LBGI informed c.500,000 customers that they would receive a discount based on either their ‘loyalty’, on the fact they were a ‘valued customer’, or otherwise on a promotional or discretionary basis, where the described discount was not applied and was never intended to apply.
The FCA found that LBGI had breached Principles 3 and 7 of the FCA’s Principles for Businesses.