Supplementary Written evidence submitted
by the Financial Ombudsman Service
1. Natalie Ceeney, Chief Executive and Chief
Ombudsman at the Financial Ombudsman Service, and Tony Boorman,
Principal Ombudsman and Decisions Director at the service, appeared
before the Committee on Thursday 14 October 2010. At that session,
the Committee asked for supplementary information in four areas:
(a) the compliance costs for industry of handling
(b) the relationship between the number of consumer
enquiries received and the number of full-blown cases investigated,
and our views on whether consumers should be charged a fee for
using the service;
(c) a breakdown of where in the United Kingdom
cases come from, with data on the service's accessibility for
different groups; and
(d) a view from the ombudsman service on the
regulatory landscape and, in particular, the regulatory powers
that the CPMA should have.
2. This supplementary memorandum provides
further information on those four areas.
3. The direct costs of the Financial Ombudsman
Service are forecast to be £110 million in the current year.
These costs are paid entirely by the financial services industry
in the form of a levy and a case fee. In 2010-11 the levy paid
by firms amounts to £18 million (which is equivalent to less
than 3% of the total levy raised by the FSA to cover their costs
and those of the FSCS, CFEB as well as our own). The case fee
in the current year is £500 per case, and the first three
cases a year for each financial business are free. In the previous
financial year more than 95% of FSA regulated firms paid no case
fees at all.
4. But, of course, these figures give a misleading
impression of the total cost to the industry of handling complaints:
Only a small proportion of complaints
made to firms ever come to the ombudsman service. FSA figures
show that firms received 4,344,109 complaints in the year to 30
June 2010. The number of cases received by the ombudsman service
was under 4% of this number163,012 in the last financial
In around half the cases we investigate
we award redress to the consumer which may range from a modest
amount up to (in a few cases) the maximum of £100,000 that
we have power to awardalthough the majority of awards are
at the lower end of that spectrum.
If they are doing their job properly,
firms should take account of ombudsman decisions in previous cases
when dealing with other complaints they receive, so ombudsman
decisions may have an impact on many other cases which never get
us far as the ombudsman service.
5. However, it would be wrong to regard the
cost to the industry of handling complaints, whether they come
to us or not, as "compliance" costsas if they
were something imposed on them from outside. A proportion of complaints
are, of course, vexatious. But many complaints refer to things
the firm should never have been doing in the first place, either
because it was in conflict with the financial business's legal
or regulatory responsibilities or because it was against any basic
principle of customer service. The redress we award is usually
intended simply to put the customer back in the position they
should have been in the first place.
6. The rules about how firms handle complaints
from consumers, and the wider handbook of rules and regulatory
requirements, are determined by the FSA. Those rules are set by
the FSA following consultation and cost benefit analysis. Our
own responsibilities under the Financial Services and Markets
Act are focused on resolving promptly and with a minimum of formality
those individual complaints that are referred to us by consumers.
In this evidence, however, we have looked across the whole system,
working from the basis of our own experience in resolving individual
7. A critical part of our work is feeding back
to regulators, firms and customer groups the experience we have
gathered from complaints about how problems can occur in financial
services and how complaints can be handled fairly. We work closely
with firms and customer representatives to ensure that our decisions
have the intended impact and that there is an opportunity for
similar problems to be avoided in future. This does give us some
influence over the total costs of complaint handling, and an opportunity
to help firms to reduce overall costs, and the industry improve
overall customer satisfaction.
8. The following paragraphs look at the six
main drivers of the cost of complaint handling for firms in more
detail, together with the steps we are taking to help eradicate
Cost driver 1: How well is the underlying business
9. As noted above, complaints are an indication
that something has gone wrong in the firm. Data recently published
by the FSA has shown that the volume of complaints varies significantly
from firm to firm in a way that is not readily explained simply
by the relative scale of the businesses concerned. In our experience,
well managed firms that focus on responding to the needs of their
customers experience few complaints. In contrast, where a firm
generates large volumes of complaints, there are normally underlying
problems with the way in which its customer functions and/or products
have been managed.
10. While it might seem obvious to most
that poor management of a firm costs that firm money, it is disappointing
that some firms see complaints as an unwelcome business cost rather
than an indicator of where business improvement is needed. It
would be wrong, therefore, to see the costs of complaint handling
within firms as a "compliance burden"it has to
be seen as part of the customer service cost of running an effective
organisation, and a potential differentiator of good service.
Cost driver 2: How do firms treat complaints?
11. The Financial Ombudsman Service sees
a wide variation in the way financial services firms treat complaints.
Some see complaints as an `insight' that indicates areas for business
improvement and provides an opportunity to engage positively with
their customers. Others see complaints as a regulatory compliance
cost. However, the evidence shows that good complaint-handling
pays dividends for businesses. The TARP (Technical Assistance
Research Project), for example, found that customers who complain
and who are subsequently satisfied are 8% more loyal than if they
had no problem at all. So the costs of effective complaint handling
may actually produce a positive return for firms.
12. We work with firms of all sizes across
the financial services sector to help get this message across,
and we also publish data to show firms the differences between
good and poor levels of complaints referred to us. Positively,
we are already seeing firms changing their practice to deal with
complaints more swiftly, which not only lowers their costs, but
is far more likely to retain the loyalty of that customer.
Cost driver 3: Customer reactions and claims management
13. Of course, complaining is about the
reaction of a customer to the actions of the firm. In our experience,
most customers try to avoid complaining. Indeed raising a "formal
complaint" against a large financial institution can be a
daunting experience even for the most capable of customers. One
of our key objectives is to ensure that our service is accessible
to all customers that need it. But, of course, there are a small
minority of customers who raise vexatious disputes. The ombudsman
service dismisses these promptly. Similarly, we have a front-line
contact centre which is expected to deal with around one million
customer contacts this year, which allows us to give many consumers
the information that they need on the phone, without needing to
take their issue further into a formal complaint. Our goal is
to only take on cases where there is a genuine dispute to be resolved.
14. The past decade has seen the growth
of claims management companies (CMCs)businesses who take
on complaints for customers in exchange for a fee paid by the
customer. The service we provide is informal and accessible, designed
to ensure that consumers do not actually need assistance from
third parties, such as CMCs. CMCs can drive perceptions of a "compensation
culture", encourage vexatious or unnecessary complaints,
and add unnecessarily to the costs of both customers and firms
by the antagonistic way in which some pursue complaints. But CMCs
can also provide a helpful service for some customers who feel
unable (perhaps because of time constraints, or lack of confidence)
to raise a complaint against a financial firm. And CMCs, through
their marketing, can help draw customers' attention to cases of
widespread detriment and customer concern.
15. There is clear concern within the financial
services industry that CMCs are adding to the total cost of complaint
handling across the sector. Our view, from seeing the CMCs at
close hand, is that, like any industry, there are good companies
and poor companies in the sector. Poor CMCs are bringing the good
ones into disrepute. Regulation of the CMCs is the responsibility
of the Ministry of Justice, not of the Financial Ombudsman Service
or the FSA. We believe that stronger and more effective regulation
of the CMC sector would both reduce the total compliance costs
and improve the experience for firms and consumers alike.
Cost Driver 4: the rules and requirements surrounding
16. While complaints are an inevitability
in any industry, every industry structures the rules for handling
complaints differently. In the financial services sector, there
is a formal approach, codified in the dispute resolution (DISP)
section of the FSA Handbook, for the way in which firms need to
handle complaints. The responsibility for making the complaint-handling
rules and overseeing how firms operate them is that of the FSA.
17. Our view is that the financial services
sector does appear to have become overly "rule bound".
This is not just a regulatory issue thoughwe see cases
where the firm will argue to us that "the rules didn't say
that I couldn't do X". But sometimes X is clearly against
the general law which applies alike to regulated firms and unregulated
businesses, and often X is clearly against any basic principle
of customer service. In the supermarket sector, for example, it
would be considered ludicrous if Sir Terry Leahy considered it
a regulatory burden that his staff had to deal with complaints
that say his company's meat products kept going off, or if he
were to question "where in the rules does it say meat needs
to stay fresh?". He would of course do the reversefix
the products, and do so without the need for regulatory intervention.
18. Inevitably, the rules-based culture
endemic in the sector does create costs for all concerned. It
allows poor customer service to be tolerated, where "compliance"
and "rules" overtake common sense. Moving away from
this culture requires a different mindset across the whole sector.
If this shift could be made, it would both reduce costs and improve
Cost Driver 5: Costs of dealing with the Financial
19. Under the rules set by the FSA, financial
firms have up to eight weeks to resolve their customer's complaint.
Only if a firm has issued its final decision on a complaint (or
has failed to do so within eight weeks) and the customer refers
the matter to us, can the ombudsman service consider a complaint.
So firms have an adequate opportunity to resolve matters without
the need for the ombudsman to be involved.
20. There are two ways in which firms could
reduce the number of complaints that come onto the ombudsman service.
First, some firmsincluding some large groups (as our published
data shows)could change their practice whereby they reject
significant numbers of cases that they know or should know the
ombudsman service will uphold, presumably hoping that some consumers
will just give up. Second, many firms are poor at explaining thingsso
that, in many of the cases where we do not uphold the complaint,
it is only when the consumers get to the ombudsman service that
they receive a clear explanation of why their complaint is misconceived.
21. If a complaint is referred to the ombudsman
service the firm will, of course, incur some additional administrative
costs. First, it will normally incur a case fee of £500 if
it has already had three cases with the ombudsman service that
year (the first three cases being free). In our last financial
year, more than 95% of FSA-regulated firms paid no case fees to
the ombudsman service at all. More than half of all the case fees
were paid by just four of the UK's largest financial groups.
22. Second, the firm may incur some additional
administrative costs of its own as a result of the need to respond
to our investigations. But generally those costs should not be
significant for a firm that has already complied with the FSA's
requirement for it to carry out an adequate investigation of a
complaint when it is first referred to the firm. Where the firm
has done what FSA requires, it should usually have the information
we need on hand in its complaint file.
23. Our costs are significantly lower than
the costs of using the civil courtsas we explained in our
evidence before the Committee. Importantly, we don't require lawyers
to represent either consumers or firms, which reduces the total
cost to firms compared to working with the courts. We do, particularly
with smaller firms who are unused to using the ombudsman service,
sometimes see firms expecting to engage with us in a very legalistic
way, which incurs costs for the firm concerned. We are working
across industry, and particularly with trade associations, to
stress that firms do not need to do this, so that we can reduce
their costs of engaging with us.
24. Sometimes, however, the firm's perception
of the costs it needs to incur in handling complaints fairly is
based on misapprehensions about the actual approach that the ombudsman
service takes. Certain myths seem to persist and can shape perceptions
of "compliance costs". For example, whilst it is not
helpful if firms no longer have records of transactions, this
is far from necessarily fatal to their ability to defend complaints
about those sales.
25. We recognise that false perceptions
of requirements can be a significant issue in shaping business
costs. We therefore take considerable care to explain our decisions
and "bust myths". We do this, for example, through our
on-line technical resource which clarifies and illustrates our
approach to the various types of complaint that we see most frequently
26. We acknowledge that the control of our
direct costs is important for both firms and consumers. That is
why we are mid way through an internal cost reduction programme
and, among other things, why we have commissioned a value-for-money
review by the National Audit Office.
Cost driver 6: Cost of redress
27. In around half of the cases we investigate,
we award redress to the consumer, which may range from a modest
amount up to (in a few cases) the maximum of £100,000 that
we have power to award. The majority of awards are at the lower
end of that spectrumin PPI cases, for example, the average
award is around £2,500. It is important to note that our
awards are invariably intended simply to put the customer back
into the position they would have been in but for the error by
the financial firm. We do not "fine" or penalise financial
firms, rather our awards are restorative.
28. A common concern we encounter from industry
is that of `back book liability' from a single ombudsman service
decision. In short, firms can become concerned that a single ombudsman
service decision will require them to review all of their sales
practice or product in an area, with potentially significant costs.
It is certainly true that, on occasion, we encounter cases which
all stem from a single underlying issueand where it would
be sensible practice for the firm to learn from it, and apply
the lessons from our decisions more widely. Typically this occurs
in cases of systemic failureas with mortgage endowments
and PPIwhere the regulator is normally heavily involved.
So costs here might more accurately be seen as responding to such
systemic failures and not around the cost of ombudsman decisions.
But whilst they receive a great deal of attention, such circumstances
are relatively rare. In the majority of cases, we are simply looking
at the individual circumstances of the case, and our findings
will have no bearing on the next case. We are working with trade
associations and firms to explain this clearly as we believe it
will help firms to reduce their concerns over the costs of redress.
What we are doing to help reduce the total cost
29. Since the ombudsman service was established,
we have actively shared our knowledge and experience with the
outside worldto help consumers and firms settle disputes
without the need for our involvement, and to try to help prevent
the need for complaints in the first place. Enhancing the transparency
of our work can only assist firms and customers better understand
the reality of what we doand hence reduce the need for
cases to be referred to us. As we said at the committee hearing,
we believe that more transparency will help firms and consumers
alike do even more to reduce complaint volumes, and to learn from
the underlying issuesall of which will reduce costs.
30. We publish data about the volume and
outcome of cases both by product type and by major firm. In addition
to the on-line technical resource mentioned above our technical
helpdesk handled over 16,000 queries last year in an effort to
assist firms and customer advisors resolve cases without our formal
involvement. We describe our general approach to topical and emerging
issues through our ombudsman news publication, and by talking
to individual firms and trade associations at meetings and seminars
on a range of complaint related topics.
31. In respect of our own costs and plans
we consult each year with key stakeholders about our plan and
budgetdescribing our plans for the year and the costs that
this will impose on firms. As mentioned above, we are actively
looking at ways to reduce our costs and to improve our efficiency,
and we have commissioned an external value-for-money study by
the National Audit Office in order to provide assurance that our
service is delivered efficiently and effectively.
32. The Committee asked about the relationship
between the number of consumer enquiries we receive and the number
of full-blown cases we investigate, in the context of whether
consumers should be charged a fee for using the service, together
with a breakdown of where in the United Kingdom cases come from,
with data on the service's accessibility for different groups.
The Annex to this memorandum gives the statistical evidence requested,
using data that is found in our Annual Review for 2009-10.
33.The data in the Annex shows that the consumers
who used the ombudsman service in 2009-10 broadly reflected the
distribution of the population across the UK, the proportion from
minority ethnic backgrounds and the proportion with some form
of disability. It also showed a steady socio-economic shift in
consumers using the service, with a higher proportion now coming
from semi-skilled or skilled (rather than professional or managerial)
backgrounds. The data also showed that the age profile of users
broadly reflected the ownership of financial products across the
population. The Annex also explains how the number of complaints
received by firms translates into the number of enquiries, investigations
and ombudsman decisions that we handleshowing that the
complaints we handle is a very small proportion of those that
Free access for consumers
34.We believe that there is a strong case for
continuing to provide free access to the ombudsman service for
consumers. Accessibility to the service is fundamental to the
objective of building confidence in the financial services sector.
Requiring consumers to pay an up-front fee for using the service
would be unlikely to deter the small number of vexatious consumers
that approach the service (whose complaints we summarily dismiss
in any case), but would instead be likely to deter consumers with
financial hardship with more meritorious complaints.
35.In our experience, the charging structure
that the ombudsman service has for many years adopted (primarily
a case fee payable for the fourth and each subsequent case referred
in relation to the financial firm and a levy payable by all firms
by reference to size), has been generally supported by financial
firms as a practical and fair means of recovering the service's
costs. It is worth noting that the voluntary ombudsman schemes
established by the banking and insurance industries before the
Financial Ombudsman Service was set up adopted very similar fee
structures and did not make any charge to consumers.
36.The suggestion of a fee or deposit payable
by customers is made from time to time by some commentatorswho
suggest that it would deter vexatious or unnecessary complaints.
We doubt that in practice this would be the impact. In our experience
the determined complainant is unlikely to be deterred by a fee
(after all far larger fees do not avoid vexatious litigants appearing
in the courts). And the administration of small fees or deposits
could add significantly to ombudsman service overheads. But, more
significantly, a fee would detract from the assurance that the
ombudsman service provides that if things go wrong there is an
independent, accessible, impartial service that is free to customers
and available to resolve complaints. It is a significant part
of the recognition criteria adopted by the British and Irish Ombudsman
Association that "those complaining to the Ombudsman should
be entitled to do so free of charge".
37.In the particular circumstances of the financial
services sector, consumer fees are likely to be a significant
barrier for many consumers with meritorious cases, particularly
those who are in financial hardship. Equally, just because some
consumers pursue their complaint in an unfocused way that may
seem unreasonable to a firm does not mean that the case has no
meritor that the complaint should be categorised as "vexatious".
In fact, in 2009-10 we concluded that only 0.4% of our total caseload
could be categorised in that way.
38.Inevitably many of the perceptions of the
impact of the work of the ombudsman service have been set against
the background of mass failingscomplaint issues like mortgage
endowments, splits and PPI. In these cases large volumes of complaints
were made but regulatory solutions were, for whatever reason,
slow to emerge. In such circumstances the ombudsman service has
needed to continue to make decisions on complaintsdecisions
that some have seen as filling a regulatory vacuum. The absence
of clear and effective mechanisms for regulators to handle these
mass failings has led to particular pressures on the ombudsman
service over the past decade.
39.So, in our view, a critical component of
the regulatory structure going forward is that there are clear
mechanisms for dealing with such cases in future. That would mean
not only ensuring that the new regulator has an effective power
to address "back book" issues (similar to the new-style
s404 enacted in the Financial Services Act 2010), but also a wider
armoury that delivers effective deterrence and credible redress
40.There is, of course, a wider public policy
debate about the appropriate weight of the various checks and
balances FSMA puts in place over regulatory decision making. But,
from our perspective, the present system has been too slow to
respond to developing pressures and has in consequence too often
left the ombudsman service as the sole means of safeguarding customers
when more concerted action on redress would have been appropriate.
If those powers are not in place within the reformed system then
the ombudsman service will need to continue to fill a policy and
regulatory vacuum by resolving thousands of individual complaints
on the basis of what is fair and reasonable in all the circumstances
of the case.
41.The ombudsman service will continue to play
an important role in this new architecture. Our ability to respond
rapidly and fairly on individual complaints is a critical safeguard
for customersregardless of any wider background to their
case. However, we recognise the wider benefits that can be achieved
for all parties from broadly based regulatory settlements in areas
of mass claims. The ombudsman service has been supportive of the
new powers that the regulator has been given (Section 404) to
enable the ombudsman service to be positioned clearly in line
with a regulatory decision on general redress. And we continue
to work with the regulator and others to find solutions to systemic
issues. But we would urge the Committee to resist any approaches
that suggest that the ombudsman service automatically "put
on hold" cases when there are in the view of some parties
wider issues that should be explored. If the ombudsman service
were required to put case handling "on hold" whilst
systemic issues were investigated by regulators, the service would
be paralysed across significant parts of its workload. The result
would be significant consumer detriment. The answer to the issue
of how we deal with systemic issues is for us to improve the regulatory
architecture to enable swifter action, not to paralyse the body
which is dealing with the consumer detriment in the meantime.
42.As we contended earlier, this set of regulatory
powers should not be a regulatory armoury built around the need
for an extensive rule-book. That simply encourages a "tick-box"
compliance approach by many firms, and leads some firms to see
treating customers fairly as a compliance issue rather than simple
good business sense as in many other sectors of the economy. In
our view, the regulator's armoury would be more effective if it
were instead one which recognised that transparency can be a more
powerful tool than traditional rules-based regulationwhere
both the successes and failings of firms are "out there"
for all to see, and where both the regulator and ombudsman service
can support good business behaviour by being given, and using,
powers to be more open about things that they see.
43.Consistent with this, we continue to believe
that the existence of an independent ombudsman service at arm's
length from the regulator is an important way of ensuring proportionate
and risk-based regulation. The regulator will be better able to
focus on the key risks to consumers as long as there is an ombudsman
service in the background that is capable of resolving the day-to-day
disputes between firms and consumers that arise. To that extent
the ombudsman service can, without itself being a regulator, provide
an effective "nudge" towards fair and reasonable behaviour
by firms without the attendant compliance costs.
The following tables give a breakdown of where
the consumers who use the Financial Ombudsman Service come from
and what groups they belong to, and give a breakdown of the outcomes
of the inquiries that the service receives.
OVERVIEW OF CASES RECEIVED AND RESOLVED BY
THE FINANCIAL OMBUDSMAN SERVICE
Case Handling Process
|Initial enquires and complaints from consumers handled by our Customer Contact Division
|New cases referred to our adjudicators and ombudsmen for further dispute-resolution work
|Total number of cases we resolved||166,321
|Cases resolved through mediation, recommended settlements and adjudications
|Cases resolved by our ombudsmen making formal decisions at the final "appeal" stage of our dispute-resolution process
Data published by the FSA show that financial firms received 4,344,109
complaints in the year to 30 June 2010and these numbers
do not include complaints which the firm is able to resolve by
close of business on the next business day. The ombudsman service's
processes are designed around the principle of "subsidiarity",
whereby a complaint should best be resolved at the most local
possible levelpreferably by the firm itself direct with
the consumer. For the small minority of complaints that ultimately
reach the ombudsman service, we first "triage" them
to see if they can be resolved quickly and without our formal
involvementor if they can be dismissed straight away as
vexatious. This means that only around one is six of these enquiries
need to be dealt with formally by the ombudsman serviceusing
mediation, recommended settlements and adjudications as appropriate.
And of those, only 6.5% in 2009-10 were "appealed" by
either party to the final stage of our dispute-resolution processa
decision by an ombudsman.
WHERE DO CONSUMERS LIVE WHO COMPLAIN TO US?
|Region where consumers who complained in 2009-10 live
|South East (Including Greater London)||29
|Living outside the UK||2
The location of people using the ombudsman service continues
to broadly reflect the spread of the population across the UK
as a wholealthough a proportionately higher number of people
from Wales and London used the service and fewer complaints came
from Scotland and Yorkshire. There was generally a similar pattern
of complaints across all areas of the UK, although a higher proportion
of complaints from the North related to PPI than in the South.
WHAT WAS THE SOCIO-ECONOMIC BACKGROUND OF CONSUMERS WHO
COMPLAINED TO THE OMBUDSMAN SERVICE IN 2009-10?
|C1/C2 skilled and|
There has been a steady socio-economic shift in the consumers
using the ombudsman service. Over the last three years, the proportion
of complaints from skilled and semi-skilled workers has risen
by 21%, while those from professional and managerial backgrounds
have decreased by 23%. We have seen a significant increase in
complaints involving current accounts, overdrafts, credit and
PPIproducts which are held by a wide socio-economic range
of consumers. Almost two thirds of complaints to the ombudsman
service about PPI were from consumers in socio-economic groups
C1 and C2.
BREAKDOWN OF THE 14% OF CONSUMERS WHOSE DISPUTES WE SETTLED
IN 2009-10 THAT HAVE TOLD US THEY HAVE SOME FORM OF DISABILITY
|Disabled consumers who complain to the ombudsman
|Arthritis and manual dexterity difficulties
|Heart and circulatory problems (eg stroke)
|Respiratory disease and breathing difficulties (eg asthma)
|Mental health issues||6
|Organ and nervous system disorders & disease (eg diabetes, MS)
|Learning difficulties (eg dyslexia)||2
Being accessible is something the ombudsman service takes
very seriously. A person's background or ability should not act
as a barrier to having their complaint considered fairly and impartially.
The 14% of consumers that told us that they have some form of
disability is in line with estimated number of disabled people
in the UK. Many of our disabled users do not ask foror
requireany adjustment in the way we deal with their case.
But we ask all users when they first contact us whether they would
like us to adapt the way we communicate with them, to meet any
particular needs they may have. This might include providing information
in, for example, Braille, large print, sign language recorded
on DVD, or using Text Relay.
ETHNICITY OF OUR WEBSITE USERS IN 2009-10
|What ethnic background are our website users?
The proportion of people who brought complaints to the service
and who defined themselves as belonging to a non-white ethnic
group broadly reflected the figure for the population as a whole.
However, our research shows that consumers from minority ethnic
backgrounds are generally less likely to know about the ombudsman
service, although this varies significantly between different
communities. We have therefore focussed our outreach activity
to reflect this, for example through our long-term relationships
with ZEE magazine and Black History Month. We have also worked
with the traveller and gypsy community, following complaints about
the way in which firms require proof of address and identity.
We have also seen similar issues in our work with the migrant
WHAT AGE WERE CONSUMERS WHO COMPLAINED TO THE OMBUDSMAN
|Age of Consumer||%
| Under 25||4|
Two thirds of consumers who use the service are between the
age of 35 and 65. Around half the UK population is between these
ages. This "over-representation" of people in the middle
age brackets reflects the fact that they are more likely to own
a wider range of financial productsand are also more likely
to know about their consumer rights, including their right to
complain to the ombudsman service. However, almost a quarter of
complaints during the year about investments were brought by consumers
over 65. And consumers under 25 were proportionately up to three
times more likely to complain to us about car or motorbike insurance
compared with all other age groups.