Financial Guidance and Claims Bill [HL]

Written evidence submitted by Franklyn Hughes Limited (FGCB06)

The Financial Guidance and Claims Bill [HL] 2017-19 Part 2

1. Background

We are a claims management company ("CMC") based in Jersey, The Channel Islands, providing financial claims management services to consumers in the United Kingdom. We specialise in packaged bank account claims but also undergo payment protection insurance claims for eligible clients. We have been following the progress of the Bill through the House of Lords and now the Commons with great interest. The company is directed by people with many years’ experience in the claims industry. One is a former claims management officer with the Claims Management Regulation Unit.

We would like to place the below submission before you for your consideration.

2. Executive Summary

· There has been discussion that packaged bank account claims and other financial claims should also attract the interim fee-cap of 20%. We believe that various commons members, particularly the Labour MP for Oldham East and Saddleworth, Debbie Abrahams, are greatly mis-informed as to the simplicity of packaged bank account ("PBA") claims and we will set out why this is so.

· The clarion call that all "cold-calling" should be banned is misguided and tars those legitimate, compliance businesses with the same brush as unscrupulous and criminal activity. We will attempt to show that Regulators have ample resources and tools to tackle this malpractice and that there is no need for a blanket ban.

· The transition of regulation of CMC’s to the Financial Conduct Authority ("FCA") seems likely to occur in 2019. In the House of Lords an amendment was introduced to set an interim fee-cap of 20% excluding VAT for PPI claims. We will look to show that this is unnecessary and inappropriate. Coupled with the first item to be discussed, it is clear that this has not been properly thought out by the Lords and Members of Parliament.

· Clause 28 and 29 include a time period of implementation of the interim fee-cap of within two months of Royal Assent. We will argue that this arbitrary time period is unreasonable and does not allow any time for legitimate and diligent CMC’s to be able to adjust their commercial models; output and working processes to accommodate this.

3. PBA Claims Similar to PPI Claims

i. The Regulator originally attempted to justify the inclusion of Packaged Bank Account Claims within the term "Bulk Claim" (for which it was initially proposed to place a fee ceiling of 15%) based on very little evidence.

ii. We believe that Franklyn Hughes is one of the only businesses that focuses mainly on these types of claims. We have set up relationships with all the major banks and have been informed that we make up the bulk of PBA complaint referrals. Having also had extensive experience within the PPI reclaiming industry, we are in a good position to assist in explaining the differences between these two types of claims and with respect, the flaws in the Regulator’s (and now certain members of the House’s) reasoning.

iii. Whilst the rationale has centred around the complexity of the claim type, we believe that this definition has been formulated simply based on the number of claims submitted to financial institutions. The fines imposed by the FCA in respect of the mis-selling of PPI and their subsequent tardiness and negligence in effectively dealing with PPI claims; the expenditure of considerable resources by The Financial Ombudsman Service ("FOS") to manage the numbers of complaints received; the setting aside of billions of pounds by these institutions to compensate mis-sold consumers and the frequent calls made to the FCA by banks and their trade body to set a time limit by which to complain clearly and unambiguously points to this.

iv. The financial claims industry was created by in large by the systemic and toxic mis-selling of insurance by all of the major banks in the UK and claims management companies ("CMCs") have been responsible for obtaining the vast bulk of PPI redress thus far. We do not believe that anyone could argue that if it had not been for CMCs the vast majority of consumers would have been compensated. The recent Financial Conduct Authority ("FCA") Consultation document has stated that 75% of PPI policies remain unclaimed for. This emphasises that the majority of those who, potentially knew that they had PPI, have not pursued a complaint –

v. There are many examples where UK banks have attempted to restrict the ability of CMCs to operate and to rightfully claim compensation on behalf of their clients: the arbitrary time-limit of letters of authority; difficult and cumbersome PIR processes; the judicial review brought by the British Bankers Association in 2011 and the constant lobbying of government to declare a "time-bar" for PPI mis-selling clams are but a few.

vi. The subsequent proposals by the FCA in light of the Plevin case to only consider a non-disclosed commission of more than 50% as being unfair clearly shows how financial institution and CMCS are treated differently. Bearing in mind that this relates only to an undisclosed commission whereas the proposal to impose a fee-cap is where currently CMCs are obliged to clearly and transparently disclose their success fee evidences such a marked imbalance of proportionality.

vii. In respect of PPI claims, because of the secretive and undisclosed habit of adding the PPI element of a financial product to the total debt to be repaid, the majority of consumers who had been mis-sold PPI were not even aware of its existence. Exposing an individual to a loss, with the intent to gain oneself dishonestly is Fraud as defined by Section 2 of the Fraud Act 2006. The test of dishonesty is one of reasonableness. Would the ordinary person have realised that this secretive and undisclosed habit of adding PPI for the purpose of reward by way of commission was dishonest? Furthermore, should the staff, working in the financial services industry that ought to have the interests of the consumer at the forefront of their minds, not have realised what they were doing was dishonest? The answer to this would probably be yes and therefore CMCs have an important role in ensuring justice is carried out. The role of CMCs in submitting data subject access requests to establish whether or not PPI was present clearly empowered the UK public to seek recourse and this would not have been possible without the existence of CMCs.

viii. The natural conclusion to be drawn is that claims management companies (and hence the general UK public who are contacted and marketed by them) are being forced to be deprived, not only in the fact that millions have been duped, misled and defrauded but also will not be effectively able to exercise or even be aware of their right to complain simply because the banks have been grossly negligent, if not downright fraudulent, in selling this toxic product. Inevitably we need to ask ourselves the question: would these issues ever have come before the House if this, the largest mis-selling scandal in the UK finance industry had never occurred? The obvious answer is no. This argument is further supported by the fact that the proposal is to only impose the draconian fee cap on these types of financial mis-selling claims rather than for any other types of financial claims clearly because the numbers of those pale into insignificance when compared to PPI and, one could argue to a lesser extent, PBA.

ix. There are many other examples of potential financial mis-selling. Recently there was an article regarding the potential mis-selling of Personal Contract Purchases ("PCP")

We are not alleging these allegations are valid but with "an estimated one million cars sold on PCP deals last year alone" now the big personal finance scandals might be PPI and PBA but next year they could be PCP’s; mortgage interest rates miscalculations; overdrafts; critical illness insurance or life insurance. To decide now to define only two types of mis-selling claims as "bulk claims" is premature and unreasonable.

x. The government has had almost 12 years to act but has only now finally succumbed to the pressure exerted by the very financial institutions that have been responsible for this scandal in the first place. The House, the Regulator and Carol Brady (in her review of Claims Management Regulation) have been at pains to state that the proposals are not aimed at eliminating CMC’s but from our perspective, these proposals are aimed at exactly that. Our experience in the PPI reclaiming industry has shown us that 69.7% of the consumers we have helped reclaim compensation for were adamant they did not have or were not aware that they had PPI attached to their loans, credit cards or mortgages. Were it not for us marketing to them, the final bill for compensation would have been less than half of what it will be and these consumers would never have received what was rightfully theirs.

xi. It is extremely revealing that the Lloyds Banking Group were supposedly invited to produce and distribute a briefing to the Commons before the second reading and were congratulated for this. Lloyds have paid out a staggering £18.1bn for mis-selling PPI to the UK public. The FCA issued its largest ever retail fine of £117m to Lloyds Banking Group for failing to treat their customers fairly when handling Payment Protection Insurance (PPI) complaints between March 2012 and May 2013. Lloyds Banking Group have the most to gain by the draconian measures proposed tom restrict and curtail the UK public from seeking and obtaining proper redress.

xii. In addition is would appear that the Lloyds Banking Group have a disproportionate influence on Members of the House. I quote the Hansard on the Second Reading where Neil Gray (Airdrie and Shotts) said the following: "Lloyds Banking Group has highlighted that, although a cap on the fees that CMCs can charge consumers on PPI claims is welcome, CMCs are bringing other types of claims on behalf of consumers that potentially require strengthened ​regulation-packaged bank accounts, for example, which are current accounts that come with a package of extra features, from mobile phone and travel insurance to better rates on overdrafts and loans." With the greatest of respect, neither Lloyds nor the Mr Gray have had sight of the responses provided to the Regulator which informed his decision to separate PPI from PBA claims and this simple assertion, based solely on the view of one interest group – the Banks – is irresponsible.

xiii. Packaged Bank Account claims are not the same as for Payment Protection Insurance. We will further discuss the differences we have found ourselves but would like to first quote the Regulator himself.

On the 3rd of July 2016 he published CMR Special Bulletin Packaged Bank Accounts and I quote therefrom:

· "A PBA is not the same as a payment protection insurance (PPI) policy.

· Through contact with your customers and research you should be developing a good understanding of each of the PBA products on the market and associated benefits which should help you gather the right information from your client and present a complete complaint.

· There are usually more elements to a PBA than a PPI policy and therefore more facets to a PBA complaint.

· You must complete a comprehensive ‘fact find’ with your customer in order to establish what they understand the benefits to be, whether those benefits would have been useful to the client at the time of the sale and/or whether the client had taken advantage of any of the benefits attached to the account.

· As well as whether the PBA was suitable for your client you must also gather what information they recall about how the PBA was sold to them. The client may have documentation about the account or be able to access it online so you should make appropriate enquiries with your client and request documentation where available.

· Having obtained the information from your client, you should be in a position to make a detailed and specific complaint to the bank. The complaint should set out the circumstances around the sale of the PBA and clearly explain why the client believes the PBA was mis-sold to them.

· The Financial Ombudsman requires you to provide accurate, as complete as is possible, and specific information about each individual complaint. We expect you to provide the same standard of information to the bank when initiating the complaint. Failure to do this is likely to be a breach of General Rule 2b which requires you to make representations to a third party that substantiate and evidence the basis of the claim, are specific to each claim and are not fraudulent, false or misleading. Using generic, non-specific letters or short checklists to make complaints in the first instance is unacceptable and also likely to be in breach of this rule.

· As well the details of the complaint, you should provide the Financial Ombudsman with the reasons why you think the business got it wrong. It is not enough just to say you disagree with them.

· If you are not using this form (the FOS PBA Questionnaire) when escalating complaints to the Financial Ombudsman, not completing it fully, or failing to explain why you think the decision was wrong, you will be in breach of General Rule 2c.

· We expect you to have a good knowledge of your cases that are currently with Financial Ombudsman. Where decisions are made on common facts, you should be able to review whether the same principles will be applied to other similar cases. Where this has resulted in the Financial Ombudsman agreeing with the final decision of the bank, we expect you to take appropriate action in respect of similar cases. The banks are expected to do the same for upheld complaints."

xiv. We treat PBA complaints in a completely different manner to PPI claims:

· Based on our collective experience PPI complaints are, by in large, a lot simpler to pursue. As indicated previously, almost three quarters of consumers are unaware of the existence of PPI on their loans, credit cards or mortgages and only if and when a data subject access request is made do we (and the client) become aware of its existence and this forms the basis of the complaint. For this reason, there cannot be an extensive fact-finding exercise when clients are engaged, unlike with PBA claims.

· There is no requirement to submit the FOS Questionnaire to the bank for PPI claims but we do this for all our PBA claims and so therefore a thorough questioning of the client is essential in order to present a complete and comprehensive account of the circumstances of the sale.

· For PPI claims there is no requirement to submit detailed argument to FOS upon referral but for PBA claims, I personally vet all referrals made to FOS to ensure that we are tackling the reasons for rejection by the banks.

· We have employed staff with experience in the financial industry to work and process these claims.

· We analyse the results of our FOS referrals to identify trends and rationale for their decisions better inform ourselves of their criteria.

The assumption that a fee cap to the degree proposed for "bulk claims" would be suitable for PBA claims in the same way than for PPI claims, is, with respect, flawed.

xv. In order to properly analyse the impact of the proposals on businesses and consumers and to consider the differences between PBA and PPI claims, the Regulator’s initial impact assessment ought to have encompassed, particularly with regards to the premise of a no win no fee arrangement with consumers, the following components and considerations: the different average compensation amounts for PBA and PPI Claims; the relative success rates and the differing cost bases. The average offer value for a PBA claim is considerably less than that of a PPI claim. Since we began in November 2015, our highest offer has been approx. £4 500 whereas with PPI I am personally aware of some offers exceeding £50 000. Our current average offer per client is £865 where for PPI the average is in the region of £1 700, almost double. This information can be verified from the ten high street banks against which we institute claims on behalf of our clients or, if you would prefer, we can provide you with a detailed breakdown.

xvi. The success rates are a lot lower than that for PPI complaints. Independent figures published by FOS show that the complaint uphold rate for PPI between April and December 2015 was 70% as opposed to 13% for PBA. The combined effect of the success rate, average fee level and the higher costs associated with processing PBA claims significantly increases the cost base for this type of reclaiming and therefore any proposal to implement a fee cap under 25% will inevitably lead to businesses such as ourselves having to assess the viability of their continued existence.

4. Outright Banning of Cold Calling

i. The MP for Croydon South, Chris Philip, amongst others, related a story regarding cold-calling in respect to a road traffic accident. This was taken up by others wanting to know why the proposed ban on cold-calling was only included in Section 4 of the Bill in regard to pensions and had not been extended to the claims management industry.

ii. Cold-calling in respect of personal cases is already effectively banned. Client Specific Rule 8 of the Conduct of Authorised Persons Rules October 2014 ("CAPR") states: "Where business is introduced to a solicitor, the business must not act in a way that puts the solicitor in breach of the rules governing solicitors’ conduct." - .

Rule 7.03 of the Solicitors Regulatory Authority’s Solicitor’s Code of Conduct states:

Unsolicited approaches in person or by telephone

(1) You must not publicise your firm or practice by making unsolicited approaches in person or by telephone to a member of the public.


Rule 7.05 Responsibility for publicity

You must not authorise any other person to conduct publicity for your firm or practice in a way which would be contrary to rule 7.

iii. Should any CMC, or anyone else for that matter, cold call consumers with the view to institute a referral to a Solicitor and subsequent personal injury claim, this would place the Solicitor in breach of their Code of Conduct and subject them to enforcement action by the SRA.

iv. Besides the above, the Information Commissioner’s Office has, in the last few years fined many firms for cold-calling, in contravention of the Privacy of Electronic Communication Regulations 2010 ("PECR"). The CMR has also clamped down on unscrupulous and non-complaint CMC’s engaging in cold-calling.

v. There are valid concerns in the House regarding vulnerable consumers. It is those exact consumers who were targeted by Banks for all these years into unwillingly, unknowingly and unnecessarily buying PPI for which they had no need or use. We have a robust vulnerable consumer policy that ensures we deal with consumers in a sympathetic and responsible manner. It is those vulnerable consumers who need the most help in reclaiming what is rightfully theirs.

5. An Interim Fee Cap

i. Clauses 27 and 28 of the Bill are to impose a fee-cap of 20% excluding VAT on PPI claims only. The arguments to not impose a fee-cap at all are appropriate here and our arguments below point to the difficulty and inappropriateness in setting an interim fee cap.

ii. The consultation by the Regulator was launched on 11 April 2016 but was concluded more than 18 months later, showing the difficulty the Regulator had in coming to his decision. . Since regulation of the claims industry will be moved to the FCA which will need to consult and decide on a raft of other considerations, the desire to set an interim fee cap, is with respect, inappropriate.

iii. There was an argument by the Regulator for a fee-cap on what he termed "bulk claims". Para 4.5 of the original Consultation states that whilst various changes to CAPR have improved the operation of the industry considerably, the level of bulk claims remains high. This points directly to the underlying reason for the fee cap - the government’s determination to lower the number of complaints made against financial institutions. If complaints are justified the government should not prevent these complaints from being made by imposing a fee cap which would have the effect of driving many, if not most CMCs from the industry. Illegitimate claims can easily be dealt with by the financial institutions and FOS – if there is no complaint then it cannot be a difficult exercise in quickly rejecting these.

iv. In para 4.6 of the Consultation document the Regulator concedes that there are only "some" CMCs that have not acted in accordance with the intention of CAPR – however a blanket fee cap will penalise law abiding, compliant and responsible businesses.

v. The Regulator has, in the past two years, introduced a raft of enforcement measures and rule changes in order to tackle rogue behaviour and take enforcement action against non-compliant businesses. The additional measures of interim fee-capping are disproportionate and unreasonable bearing in mind the short period in which the Regulator has had these enhanced enforcement powers.

vi. Throughout the Consultation document the Regulator regularly alluded to the fact that a consequence of a fee-cap will reduce speculative claims and nuisance calls. We fail to see how this will achieve this objective. All businesses within the industry are subject to the same rules regarding Ofcom regulations and PECR and it is the Regulator and the Information Commissioners Office’s responsibility to tackle rogue players and enforce compliance.  Of late they have begun to do so and this has had the laudable effect of punishing those less ethical businesses and we applaud these efforts. Tarring all ethical businesses with the same brush by imposing such draconian measures is inappropriate and disproportionate.

vii. Claims made which are unsuccessful cannot be regarded as speculative. If consumers wish an investigation to be made by a Bank into the mis-selling of what they believe to be insurances attached to their loans or current accounts, they have that right of complaint. Speculative claims are only those where there is no relationship between a consumer and a particular bank and CMCs must abide by the rules in CAPR which require a proper investigation be made before such claims be made. If CMCs are not compliant with this, then the Regulator ought to take enforcement action against those businesses.

viii. The proposal to impose a fee cap is premised on the idea that most, if not all CMCs charge a success fee. No consideration has been given to the model that charges disbursements or costs to pursue a claim regardless of whether or not the claim proves to be ultimately successful. Is the Regulator proposing that fees can only be charged where a claim is successful? An unintended consequence of this proposal by the Regulator would force many CMCs to consider this costing model and would thereby negate the fee cap and effectively cause even further consumer detriment which would result in consumers having to pay fees for a claim which proves to be unsuccessful.

ix. The Regulator has been at pains to attempt to justify the radical intervention in how charges are made based on the assumption that this will further improve consumer protection. In our view, whilst these sentiments are lauded, this action will have the opposite effect and actually contribute to consumer detriment. Many consumers have not known whether they have even been sold PPI, let alone whether it was mis-sold and CMCs have been able to employ recognised marketing and advertising campaigns to highlight this to the general public.

x. Those CMCs that have flouted the Conduct of Authorised Persons Rules ("CAPR") and other legislation (the Data Protection Act 1998 or the Privacy of Electronic Regulations 2003 as amended ["PECR"]) will not curtail their rogue behaviour simply by a fee-cap being implemented. The Regulator now has the tools to enforce compliance. Current regulations provide that there can be no "cold-calling" in person; that nobody on the Telephone Preference Service list can be called, and that CMCs must comply with CAPR. In other words, CMCs are subject to much the same rules as other regulated businesses and it is hard to see why, as a matter of fairness, CMCs should be subject to more onerous rules.

xi. By unreasonably limiting the amount that CMCs can charge consumers who have chosen to engage them to present their complaints to banks rather than complain directly will only bring about further non-compliance, as certain CMCs may seek to curb their costs to such an extent that due diligence and compliance is compromised.

xii. The very toxic nature of the widespread miss-selling of PPI in particular leads one to the inevitable conclusion that the vast bulk of consumers mis-sold to are financially vulnerable and therefore at risk. The Regulator’s proposals will stifle attempts by CMCs to reach those most affected by this scandal and effectively deprive these consumers of the right of complaint. As the FCA have themselves found through market research, banks have only investigated 25% of the complaints estimated to be out there – FCA Consultation on Time Barring PPI Complaints.

xiii. The failure by the FCA to insist upon, or the banks lack of responsibility to, proactively investigate all PPI sales made and where appropriate compensate those consumers mis-sold has vastly contributed to the scandal dragging on and the stifling of legitimate, free-market enterprise will in no way serve to protect consumers.

xiv. In our view the fundamental question that the House needs to ask is why is a fee cap justified in order to protect consumers?

a) The Regulator cites that the main rationale for intervention is to improve efficiency and quotes statistics supplied by The Financial Ombudsman ("FOS") showing that the complaint up-hold rate is higher in respect of consumers who complain themselves rather than through a CMC and that therefore the assistance of CMCs adds very little value - see para 2.8 of the Consultation document. Since these statistics are only in respect of cases referred to FOS where the financial institutions have rejected the complaints and the work involved is considerably more complex in respect of PBA claims, the Regulator ought to ask financial institutions what the comparative success rates are in respect of complaints lodged by CMCs and consumers themselves.

b) The statistics provided by FOS for the year ending March 2015 quoted in para 2.9 of the Consultation document show that were it not for the efficiencies of CMCs, 80% of consumers who had been misled and mis-sold their PPI by financial institutions would not have received redress, since only one fifth have thus far decided to complain themselves. Since banks in the UK have set aside £18.76bn (Para 2.15 of the Consultation document) the savings that banks would have made would be approximately £15bn. This points to another possible motive for these drastic proposals – the reduction in exposure by banks to compensation for mis-selling.

c) An independent review of claims management regulation by Carol Brady published in March 2016 argues (at para 2.30) that the government should not seek to regulate CMCs out of existence. The supposed justification for placing a fee cap on the amount CMCs can charge in a free economy will achieve the result of driving most, if not all, CMCs from the field.

d) Assumptions are made that consumers do not know that there are free alternatives to claiming and are ignorant as to what the complaint process entails. As with all services, consumers need to make the decision whether the service offered is value for money and whether or not they can or wish to pursue the claim themselves.

e) Client Specific Rule 10 of CAPR states that: "Before seeking to enter into a contract with a client a business must make reasonable enquiries as to whether the client has alternative mechanisms for pursuing a claim and must advise the client unambiguously of ombudsman schemes or other official means of redress." and Client Specific Rule 13 of CAPR requires that: "A business must make explicit to the client his right to seek further advice or to shop around, subject to any time limits within which a claim must be made." This is adhered to rigidly by us in our paperwork and elsewhere and the Regulator should enforce compliance thereof rather than impose a fee cap to achieve this.

f) The description of what is a "Bulk Claim" is flawed. As stated by the Regulator 14 CMCs out of 850 operating in the financial claims sector account for more than half the turnover (and presumably the claims submitted to financial institutions) in the entire financial claims sector – Para 1.11 of the Consultation document. Hence the other 836 CMCs operating in the financial sector account for the rest. The only reasonable inference therefore is that these CMCs do not submit claims in the vast numbers that the larger 14 do and so therefore the claims they submit can hardly be classified as "bulk".

g) PPI and PBA claims are classed as "bulk" whereas claims for mis-sold credit cards; unfair bank charges; unreasonable overdraft fees etc. are not mentioned. Would these then be "other financial claims"? Using the Regulator’s justification for the arbitrarily low fee cap for "bulk claims" the processing of these types of claims is hardly more complex than what PPI and PBA claims are. It would appear that the term "bulk claims" has merely been defined by how many claims of this nature have been made to the financial institutions and FOS. Should another form of widespread mis-selling be discovered then the regulator would have to again amend CAPR to include this as a "bulk claim". How will it be determined how many claims would need to be instituted for this to be classed as a "bulk claim"?   Today it is PPI and PBA – tomorrow it could be some other type of financial mis-selling by financial institutions – businesses who have brought the ugly spectre of financial mis-selling to the British public; the financial institution and various regulators should not be penalised at the exclusion and at the behest of large financial institutions.

h) In addition, Franklyn Hughes Limited has been operating almost exclusively within the mis-sold PBA market and the allegation that these types of claims are relatively straight-forward and simple has not been evidenced by us at all. In particular FOS have insisted upon CMCs formulating and providing reasons why banks have incorrectly rejected claims; numerous meetings have been held with them and banks and these cases are certainly not in the category as PPI and we contest that they be grouped together under the umbrella of "Bulk Claims" - the Regulator is invited to contact FOS for confirmation of this.

6. Two-Month Implementation Period

I. Clause 28 seeks to force the Regulator to impose the interim 20% fee cap for PPI Claims within two months of Royal Assent.

II. This decision to punish legitimate and law abiding businesses in order to tackle rogue practices with barely any notice is, with respect, unreasonable and draconian.

III. More than 18 months has lapsed since the Regulator first announced a Consultation to consider capping fees that CMCs charge consumers. As a business active in the claims management industry we have had to attempt to plan ahead in what have been very uncertain times, producing commercial model after commercial model. The Response by the Regulator dated 15 November 2017 in which he agreed that upon regulatory transition to the FCA, that body would be best placed to consider a fee cap led the industry to believe that any possible consideration of a fee cap would take place in either late 2018 or early 2019.

IV. To now suddenly be faced with the prospect of a fee cap for PPI and PBA in the next two months has thrown the industry into turmoil and whilst many in authority have professed that these regulatory changes are not aimed at regulating CMCs out of existence this is exactly what will happen.

V. Not only do we, as a company, employ people directly our outsourced partners in Leeds and Manchester, who employ in excess of 100 staff will be forced to make significant redundancies.

VI. Whilst 2 months is unreasonable, a period of 6 months would allow businesses to make the necessary business process and financial adjustments and will still occur 12 months before the 29 th of August 2019, the PPI reclaim cut-off date set by the FCA.

January 2018


Prepared 1st February 2018