online PPI resource
how does the ombudsman service assess PPI sales-complaints?
In reaching an assessment of an individual complaint, the ombudsman needs to take into account all the circumstances of the case. This will include:
- any relevant circumstances particular to the individual consumer and sale; and
- where it appears that the sales process used by the firm is designed and delivered as a standardised process, the features of that sales process.
To assist in the process of assessing the sale, we will take into account all the evidence available. This might include:
- the documentation produced at the time;
- the consumer's (or the firm's) recollections of the sales process;
- recordings of relevant phone conversations;
- sales scripts and staff training-material
- the typical outcomes of the sales process at the time; and
- information from regulatory authorities.
We need to consider the overall picture, not specific issues in isolation. So, for example, a piece of information given to a customer during a sales process cannot be read in isolation. Instead, some consideration needs to be given to:
- the point in the process at which the information was provided;
- the way in which the information was communicated; and
- the issues facing the customer at the time.
If a standardised sales process is found to have been inadequate, it may be difficult to avoid the conclusion that most complaints about sales made under that process should be upheld.