From the FSA consultation (responses due by 30th October 2009) http://www.fsa.gov.uk/pubs/cp/cp09_23.pdf
A PPI complaint questionnaire
3.28 Claims management companies (CMCs) offer to help consumers pursue their
complaints with financial services firms and the FOS, and a number of them are
currently focusing on PPI complaints. In return, the consumer has to pay the
company a fee, usually a fixed share of any redress awarded for an upheld complaint.
Obviously, this fee is money that the complainant can’t then use to help correct the
financial problem they had complained about.
3.29 Some consumers may find it helpful to use such companies. However, the obligations
we impose on firms to handle complaints fairly and without charge are designed to
ensure that a consumer can make a complaint and have it fairly considered without
needing any third party assistance.
3.30 We note that complaints that come from some claims management companies in
the form of templates (especially where these contain only brief and generic text)
do not necessarily help firms make a fair and balanced consideration of the
complaint. Firms should be able to seek more detail and supporting information,
including contacting the customer directly to get his or her recollection of events at
the point of sale.
3.31 We understand that to facilitate this, the FOS is developing during the consultation
period, in conjunction with industry and consumer representatives, the design of a
PPI complaint questionnaire which the FOS would generally require to be completed
before a referral. This will ensure both CMCs and firms do the necessary leg work
in setting out and looking into the details of the case, avoiding generic complaints
and generic rejections respectively. The equivalent mortgage endowment
questionnaire worked well to this effect.
3.32 We have also spoken with the Ministry of Justice, who regulate CMCs, to ensure
they are aware of some poor behaviours by some CMCs active in PPI complaints.
3.28 Claims management companies (CMCs) offer to help consumers pursue their
complaints with financial services firms and the FOS, and a number of them are
currently focusing on PPI complaints. In return, the consumer has to pay the
company a fee, usually a fixed share of any redress awarded for an upheld complaint.
Obviously, this fee is money that the complainant can’t then use to help correct the
financial problem they had complained about.
3.29 Some consumers may find it helpful to use such companies. However, the obligations
we impose on firms to handle complaints fairly and without charge are designed to
ensure that a consumer can make a complaint and have it fairly considered without
needing any third party assistance.
3.30 We note that complaints that come from some claims management companies in
the form of templates (especially where these contain only brief and generic text)
do not necessarily help firms make a fair and balanced consideration of the
complaint. Firms should be able to seek more detail and supporting information,
including contacting the customer directly to get his or her recollection of events at
the point of sale.
3.31 We understand that to facilitate this, the FOS is developing during the consultation
period, in conjunction with industry and consumer representatives, the design of a
PPI complaint questionnaire which the FOS would generally require to be completed
before a referral. This will ensure both CMCs and firms do the necessary leg work
in setting out and looking into the details of the case, avoiding generic complaints
and generic rejections respectively. The equivalent mortgage endowment
questionnaire worked well to this effect.
3.32 We have also spoken with the Ministry of Justice, who regulate CMCs, to ensure
they are aware of some poor behaviours by some CMCs active in PPI complaints.