Covid-19 (coronavirus)

Read more about our approach to complaints

• Investments and pensions

  We know this will be a worrying time for consumers with investments and pensions – whether they’re concerned about the risk of potential scams, or about the performance of the money they have invested. And firms who give advice, or manage customers’ investments, will also want to make sure they’re providing the appropriate support for their customers at this time.

  The FCA has reminded firmsLink to FCA website what information they can give their customers with to help them make the right decisions at this time about their investments. We’ll take this into account – alongside other considerations regarding the type of sale and suitability of advice – when deciding whether a firm has acted fairly.

• Mortgages

  When looking at a complaint, we’d expect to see that a lender responded positively and sympathetically to a borrower being in financial difficulty. Lenders should be thinking about and taking into account the following things:

  • Individual circumstances, to decide what’s fair and reasonable in the circumstances of the complaint.
  • The FCA’s most recent guidance for people having difficulty paying their mortgage during this particular timeLink to FCA guidance for financial firms. In particular, you should consider forbearance measures such as longer payment holidays, repayment plans, freezing interest, reasonable arrears rescheduling and pausing on repossessions/court action.
  • That there is no need for you to investigate further in order to agree to the payment holiday. Customers already in a payment arrangement shouldn’t be treated less favourably.
  • Any payment holiday should not be recorded on or have an impact on the customer’s credit file.
  • You should carefully listen to consumers and proactively look for signs of financial difficulty. Consumers may not always know the best way to express their concerns.
  • Even if a customer doesn’t specifically ask for a payment holiday when calling to discuss difficulty in making their payments, you should ask whether the customer would be interested in a payment holiday. 
  • Where possible, make it easy for your customers to contact you – including, where appropriate, through different channels to those you usually make available.

  Read more about our approach to the complaints we see about mortgages.

• Banking and credit

  Section 75 complaints 

  With section 75 complaints, the things we’ll look at in particular include the following:

  • When deciding what’s fair and reasonable, we’ll always consider individual circumstances. 
  • We expect card issuers to consider chargeback and section 75 claims where appropriate, regardless of how the consumer expressed their claim.
  • We expect businesses to consider whether they should pay any consequential losses. 
  • We’ll take into account whether consumers have already been able to recover financial losses from the suppliers. 
  • We expect businesses to treat consumers in financial difficulty positively and sympathetically.

  Read more about our approach to complaints about goods and services bought with credit.

  Financial difficulties 

  When handling a complaint about financial difficulty, the things we’ll look at in particular include the following:

  • When deciding what’s fair and reasonable, we’ll always consider individual circumstances. 
  • We expect businesses to treat consumers in financial difficulty positively and sympathetically, fairly and with forbearance – in line with FCA’s principles and rules (set out in the Consumer Credit Sourcebook (CONC)).
  • We expect businesses to listen to consumers and proactively look for signs of financial difficulties. Consumers may not always know the best way to express their concerns. 
  • If a consumer is facing financial difficulty, we expect businesses to consider forbearance measures such as token repayment plans, freezing interest and charges, reasonable arrears rescheduling and debt write-off where appropriate.

  • Given the extraordinary circumstances, we may expect businesses to think about additional forbearance measures alongside the above, such as payment freezes, and have regard to the temporary measures introduced by the FCA in April 2020 Opens in new windowand July 2020Opens in new window, and the finalised guidance introduced in October 2020Opens in new window. These are designed to provide temporary or longer term tailored financial relief for customers affected by Covid-19 on products such as credit cards, loans and overdrafts.

  • The FCA also confirmed targeted temporary measures to cover motor finance and high-cost credit agreements in April 2020Opens in new window and July 2020Opens in new window, which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking. The finalised guidanceOpens in new window is relevant to some of these products also.
  • We’ve issued specific guidance on this page for people having difficulty with their mortgage payments or car finance.

  Read more about our approach to complaints from consumers who are in financial difficulties.

  Car finance – and other hire purchase/conditional sale/lease/hire agreements

  The things we’ll look at in particular, include the following:

  • When deciding what’s fair and reasonable, we’ll always consider the individual circumstances.
  • We expect businesses to listen and proactively look for signs of financial difficulty. Please refer to our guidance on financial difficulty above. 

  • Given the extraordinary circumstances, we expect businesses to be even more flexible in their forbearance measures, as set out above. We’d also expect them to consider the specific needs of an individual to stay mobile at this time. The FCA confirmed targeted temporary measures to cover finance and high-cost credit agreements in April 2020Opens in new window and July 2020Opens in new window which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking. It released finalised guidanceOpens in new window in October 2020. 

  • We expect businesses to fully inform consumers of their options to exit the agreement where necessary or appropriate. Different exit options result in different liabilities for consumers. Businesses should give them a clear explanation of the different options. This is to allow consumers to understand fully the implications on the amount which would remain outstanding on their loan under each of the termination options. Businesses should also alert consumers to any impact this may have on their credit file.
  • We remind businesses that reporting to credit reference agencies should not only be accurate but also fair in the circumstances.
  • If there is a dispute about the quality of the goods, and where the normal ways of inspecting the goods aren’t available, we’d expect businesses to be flexible and use initiative in trying to resolve complaints.

  Read more about our approach to complaints about car finance. 

• Insurance

  The FCA has set out information for insurersLink to FCA guidance for financial firms during the pandemic. 

  Travel insurance 

  The things we’ll look at in particular, include the following:

  • We’ll always consider individual circumstances including the relevant policy terms, when bookings were made and when the policy was taken out.
  • We’ll take into account whether consumers have already been able to recover financial losses from their airline, tour operator, bank or credit card company.
  • We’ll consider foreign and domestic government information about travel restrictions in the same way as the FCDO advice, taking account of policy terms.
  • We’ll consider self-isolation and cancellations due to sickness in the same way as we do with ‘travelling against medical advice’.
  • We expect insurers to take a pragmatic view of decisions not to travel or to curtail a trip. We’ll bear in mind factors such as the purpose of travel, the rapid pace of changing advice and the ability of consumers to contact their insurer at the relevant time.
  • We recognise the challenges of validating some claims. However, we expect consumers to be treated fairly, and we encourage insurers to consider carefully the available evidence including credible consumer testimony.

  • We recognise that some consumers may have taken the difficult decision to cancel their trips earlier than insurers might usually expect. But insurers should consider whether a later claim would have been accepted – for example, if travel advice or restrictions would have meant the consumer would have ultimately had to cancel before departure date.

  Read more about our approach to complaints about travel insurance.

  Business interruption (protection) insurance

  For information about how we handle complaints about business interruption insurance, take a look at our separate page on our small business website. Link to business interruption insurance on SME website

  Wedding insurance

  For guidance specifically on wedding insurance, please look at our dedicated page for businesses that contains information about how we deal with complaints about wedding insurance, including complaints about Covid-19.