Eiko Heffer, Policy Manager Financial Ombudsman Service South Quay Plaza 183 Marsh Wall London E14 9SR 24 January 2012

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1 Eiko Heffer, Policy Manager Financial Ombudsman Service South Quay Plaza 183 Marsh Wall London E14 9SR 24 January 2012 Dear Eiko Heffer Re: FOS consultation - Publishing Decisions I write in response to your request for feedback following the FOS consultation paper publishing ombudsman decisions: next steps. AWD Background AWD Chase de Vere is part of the AWD Group which is one of Europe's largest independent financial services groups listed on the German Stock Exchange. Established more than 40 years ago it is now one of the UK s largest independent financial advisers. In the increasingly complex UK financial services market we are known as experts in our field. We act for individuals as well as companies and their employees, all of whom seeking to prosper financially from our tailored financial advice. We believe in giving holistic advice that complements our clients' personal financial goals. We do this by first getting to know our clients and their objectives and then offering them solutions that work towards their goals. As independent financial advisers we are free to choose products from the entire UK financial services market. Consultation response In general terms AWD Chase de Vere welcomes greater transparency from the Financial Ombudsman Service which may assist firms when deciding how to resolve complaints. The intensions around the publication of Ombudsman decisions are clearly understood, for example, it would not be in anyone s interest for the FOS to be committing resources to dealing with numerous Freedom of Information requests which could be allocated to providing a more efficient service to consumers and financial advisers. However, in providing greater transparency we are concerned that this may have a detrimental effect on firms and some consumers. We therefore feel that the outcomes of these proposals need to be considered carefully before they are implemented. Our main concerns can be summarise as follows: o We disagree strongly with the FOS assertion regarding Claims Management Companies, (CMC). We believe the availability of information is likely to lead to increased activity from CMC who will use the data to focus their activities based on trends. This is likely to increase the workload for companies and ultimately the Financial Ombudsman Service.

2 o Preparing case summaries, ensuring they are fit for distribution, managing appeals, questions and challenges are likely to increase the workload of the FOS. We believe the impact on the service has been underestimated and FOS performance will deteriorate in terms of both quality of decisions and the length of time to issue the decision. o The FSA recently introduced clarification to their expectations of firms with regards to the analysis of root causes. We consider the publication of decisions to fall within the definition of guidance and as such should be considered by firms to inform complaint handling routines. With several thousand decisions issued every year it would be almost impossible to review all decisions which may impact on the ability of firms to take account of key FOS decisions with wider implications. o The decision to withhold information and personal data relative to customers but not for financial businesses is unbalanced and not in keeping with the impartial nature of the service. There are other questions and concerns contained within the AWD Chase de Vere non-confidential response which is attached to this letter. If you have any questions regarding the response please do not hesitate to contact me. Yours sincerely Tony Bullock Head of Regulatory Policy Direct Dial: tony.bullock@awdcdv.com

3 Summary of questions & responses: FOS consultation Question 1: Do you agree with our overall approach? Are there other considerations we should bear in mind, in approaching the publication of our ombudsman s final decisions? AWD Chase De Vere ( AWD ) does not agree with the overall approach and requests that consideration is given to the following points: o Unlike Claims Management Companies, firms do not tend to refer cases to the Ombudsman as a matter of course. Only where the case is borderline and AWD strongly disagree with the findings of the adjudicator, will the decision be taken to refer. However, if in the future the disputed decision is to be published, firms are likely to adopt a far more aggressive and defensive position leading to less informal resolution, additional use of legal opinion (increased costs) and applications for judicial review. o The sheer volume of Ombudsman complaints to be published will be unmanageable for firms to assess and thereafter incorporate in their complaint handling processes, given limited resources. We propose an alternative solution which is a sector and/or product specific version of Ombudsman news. This would follow the same approach of the current publication but would concentrate specifically on certain sectors or products. The current document is useful but has limitations due to the amount of ground it must cover. An Investment version of Ombudsman News would be far more useful to Investment firms than articles relating to banking or general insurance. o Complaints can arise from advice given many years ago, with different standards, regulators, financial markets and company personnel. It is not clear what benefit would be derived from publishing complaint information relating to advice provided circa 14 years ago, for example mortgage endowments and suggest that as a minimum the date of the advice, prevailing regulator and key company information are included (as per FSA enforcement notices which gives background details of the firm). o Firms are likely to take the decisions handed down by the Ombudsman as influential in their complaints assessment processes. Unfortunately the Ombudsman s decision is unlikely to comment on the skill / competence of the responding firm. A poorly argued complaint could therefore result in an upheld complaint. What could be a one-off case for one firm may lead to another firm changing its approach, potentially incorrectly, on a much larger scale.

4 o If the Ombudsman is acting impartially, as it promotes it is, equal protection of identity should be given to both the complainant and the firm involved. Question 2: Do you agree that we should not publish the views of adjudicators - instead limiting publication of decisions to those made by our ombudsmen? Yes, AWD agrees that the views of adjudicators should not be published. Question 3: Do you agree that our published reports on cases should not normally be specially commissioned summaries, but the actual determinations made by the ombudsman? AWD agrees that a specially commissioned summary would not be necessary and the actual determinations should be used except where the arguments are highly complex, or have potential wider implications. In these circumstances a summary may be appropriate for publication. Question 4: Overall do you think our proposed approach strikes the right balances between transparency, protecting genuinely confidential information and costs of implementation? AWD considers that some of the information published could potentially be damaging to companies and lead to disproportionate impacts on smaller firms. The FOS purport to act impartially, however by protecting the client (rightly under data protection) and naming the firm with the obvious reputational damage this could bring, FOS appear to be acting as the consumers champion. There is little doubt in our opinion that certain elements of the financial press will use information in these case decisions to cast doubt on the quality of firms advice in respect of all business. The Financial Services Bill does not state that the identity of the Financial Services business should be disclosed and as such AWD feel that balance should be provided by removing details of firms and customers from the published decision. If the decision is taken to name firms some consideration should be given to highlighting the timescales since the advice was provided and whether the original firm was a legacy business.

5 Question 5: Do you think that the steps we propose are sufficient to protect consumers identities and personal information - or are there specific steps we should take? The steps appear satisfactory. Question 6: Do you agree that we should not seek to protect the identities of financial businesses? If you disagree, what other steps would you want us to take? As per question 1 and 4. The possible impact on a firms Professional Indemnity Insurance (PII) should be considered, in particular with regards to the point raised in question 1 regarding the increased expectations of the Regulator. The FOS should make enquires to ascertain the views of PII insurers and whether the proposals will bring further challenges to an already difficult market place. AWD expects PII costs to increase as a result; this does not appear to have been considered in the consultation. Question 7: Do you agree with our planned approach to the identities of third parties, including other financial businesses, professionals, other representatives and third- party businesses? AWD agrees that third parties can be protected. However it is assumed that the performance of Claims Management Companies (or similar) will be kept under review by the FOS and where claims are systematically referred to the Ombudsman the FOS will consider referring the CMC to the regulatory authority (Ministry for Justice). Question 8: Do you agree that we should reserve the right not to publish certain decisions or to exempt information in other exceptional circumstances? Where there is criminal activity involved the case shouldn t be published. Where the reasons are more subjective AWD require clarification as to what would constitute exceptional circumstances and what process will be followed to ensure all parties are in agreement.

6 AWD also expect the opportunity to exist for firms to challenge the publication of decisions and for an independent appeals process to be in place. Question 9: Are there any other considerations about safeguarding personal information that are not covered in this paper that we need to take into account? None Question 10: What impacts do you believe publications of decisions as we propose will have - on consumers, financial businesses and on our service? In summary AWD considers that the proposal in their current form will have the following effects: o Consumers - Some consumers will see this as an opportunity to make public their grievances, whilst others may be dissuaded by the prospect of the decisions being made public. o Firms - The impact on firms is likely to be disproportionate, particularly where limited resources are available to review decisions. Firms may take a more aggressive line of defence in order to keep their name out of the public domain and FOS should expect to receive more challenges in the form of judicial reviews. o FOS AWD considers the FOS has underestimated the impact on the service provided. Publication of decisions will lead to a change in behaviour of consumers, firms and CMCs in particular and AWD expects there to be deterioration in performance if FOS do not carefully prepare for the challenges this new approach will bring. Question 11: Do you agree with our approach to timing of publications? If not, when should decisions be published and why? If the proposals go ahead as planned and decisions are published, it should be once the decision has been accepted by all parties not as the decision is made. Whilst the decision of the Ombudsman is binding, there have been examples where new information has been brought to light at the eleventh hour or shortly after the determination, which has changed the decision. AWD suggest that not only is agreement reached by all parties that the decision can be published, but that a period of grace is allowed e.g. 28 days before publication.

7 Question 12: Do you agree with our approach to the form of publication? Precisely how publication is to be carried out, other than a general comment that it is likely to be on the FOS website, has not been determined. It is not possible for AWD to comment at this stage other than broad agreement that the internet is the most obvious medium of communication. Question 13: Do you have any comments on when we should start publication of decisions and what are your views on the publications of past decisions Do you agree with our approach to the form of publication? AWD do not expect past decisions to be reviewed and only new complaints received after a certain cut off date should be considered. AWD suggests the changes take place with effect on any new complaints received after 1 st January Question 14: Do you agree that we should adopt the same approach across all our jurisdictions - and specifically do you agree that we should cover our voluntary jurisdiction in the same way as our compulsory (FSA/FCA) jurisdiction and our consumer credit jurisdiction. AWD agree that voluntary jurisdictions should be included in the proposals. Tony Bullock Head of Regulatory Policy 23/11/2011

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