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EGG BANKING PLC (Egg)
Date: 9th December 2008:  
The FSA gave Egg Banking plc (Egg) a Decision Notice on 5 December 2008, which notified the firm that pursuant to section 206 of the Financial Services and Markets Act 2000 (the Act), the FSA had decided to impose a financial penalty of £721,000 on Egg. Click Here for a copy of the FSA Final Notice document.

LIVERPOOL VICTORIA BANKING SERVICES Ltd
Date: 29th July 2008:  
The FSA gave LVBS Ltd a Decision Notice on 28 July 2008 which notified them that pursuant to section 206 of the Financial Services and Markets Act 2000, the FSA has decided to impose a financial penalty of £840,000 upon them. This penalty is in respect of breaches of Principles 3, 6 and 7 of the FSA's Principles for Businesses and associated rules between 14 January 2005 and 8 August 2007 in relation to sales of Payment Protection Insurance offered in connection with unsecured personal loans.

The financial penalty imposed is for breaches of the FSA's rules in relation to the firm's sales of single premium PPI offered in connection with unsecured personal loans via its telephone sales channel. These breaches related to LVBS failure to:

  • take reasonable care to organize and control its affairs responsibly and effectively, with adequate risk management systems;
  • pay due regard to the interests of its customers and treat them fairly; and
  • pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.

LVBS did not tell customers on the telephone that PPI was optional and the paperwork provided to customers also failed to make it clear that this was an optional product which the customer could choose not to buy.

When customers realized that they did not have to buy PPI and objected to it, LVBS put pressure on customers to take the PPI by using 'objection handling' techniques. This risk was further increased by the financial incentive schemes LVBS operated for PPI sales staff.

During the relevant period, LVBS sold approximately 14,500 PPI policies at an estimated average cost of £1,600 (including interest) generating a gross PPI income of approximately £23 million.

HFC BANK LIMITED
Date: 16th January 2008:
The FSA gave HFC Bank Ltd a Decision Notice on 11 January 2008 which notified them that pursuant to section 206 of the Financial Services and Markets Act 2000, the FSA has decided to impose a financial penalty of £1,085,000 upon them. This penalty is in respect of breaches of Principles 9 and 3 of the FSA's Principles for Businesses and associated rules between 14 January 2005 and 28 May 2007 in relation to sales of Payment Protection Insurance.

The FSA has imposed a financial penalty on HFC for breaches of the FSA's Principles and rules in relation to its sale of PPI. These breaches related to HFC's failure to:

  • Take reasonable care to organize and control its affairs responsibly and effectively, with adequate risk management systems;
  • HFC's sales staff were not required to gather, and take into account, sufficient information about customer's personal circumstances and objectives when making sales. HFC's processes did not therefore take adequate steps to ensure that its personal recommendations were suitable.
  • HFC did not provide its customers with information that adequately set out their demands and needs and explained why HFC was recommending the policy. Nor did HFC require its advisers to identify the customer's demands and needs which would not be met.
  • HFC failed, in particular, to require advisers to gather and analyse sufficient information about the following: A customer's future needs and circumstances, alternative means to protect the loan, the type and level of cover required and pre-existing medical conditions.
  • HFC is a large firm which sold approximately 163,000 PPI Policies over the Relevant Period (of which 124,000 were single premium) from 235 branches (136 branches by the end of the period) across the UK

ALLIANCE & LEICESTER PLC
Date: 6th October 2008:
The FSA gave Alliance & Leicester plc a Decision Notice on 6 October 2008 which notified them that pursuant to section 206 of the Financial Services and Markets Act 2000, the FSA has decided to impose a financial penalty of £7 million upon them. This penalty is in respect of breaches of Principles 3, 6, 7 and 9 of the FSA's Principles for Businesses and associated rules between 14 January 2005 and 31 December 2007 in relation to sales of Payment Protection Insurance offered in connection with unsecured personal loans.

The breaches relate to Alliance & Leicester's failure to:

  • take reasonable care to organize and control its affairs responsibly and effectively, with adequate risk management systems;
  • pay due regard to the interests of its customers and treat them fairly; and
  • pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.
  • take reasonable care to ensure the suitability of its suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgment

The FSA considers that A & L has breached Principle 6 of the FSA's Principles of Businesses by not making it clear to customers that the PPI was optional, and by using inappropriate sales techniques that put pressure on the customer to accept the recommendation, allied with inappropriately managed adviser inducements, to encourage customers to buy PPI.

During the relevant period approximately 211,000 PPI single premium policies were sold on approximately 514,000 loans (including to customers who had initially declined PPI on their internet application), giving a penetration rate of approximately 41%.

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