PPI Commission on old secured loans re: Plevin?

BooJewels

I'm going to update this, because I personally hate it when I search for information and a thread that turns up that's of interest doesn't post any conclusion. I'd downloaded the FCA Guidance on PPI complaints (I think there's a slightly later Handbook for financial companies) from March 2017 and I've been skimming it when hanging on the phone etc. and found the pertinent bits on redress - in case it helps someone else.

It states that the three key elements of redress are:

1. The difference between the commission the customer paid and the tipping point of 50% of the premium paid
   plus
2. Historic interest paid on this portion of the premium
   plus
3. Annual simple interest at 8% on the sum of 1 + 2.

In respect of claims made during the life of the policy and whether or not these should be deducted from redress, it states:

a subsequent successful claim on the policy does not, after the event, correct the unfair relationship under s.140A that was created at point of sale by the non-disclosure of the high commission, and so, unlike in our existing approach to redress at Step 1 in DISP App 3, the claim should not be reflected in (reduce) redress at Step 2.

So that suggests that the value of any successful claim during the life of the qualifying policy would not be deducted in the same manner as they are with PPI mis-selling complaints.

Therefore the bank must think the latest of my loans may yield some redress when they get to assess it, hence writing to me about it.

BooJewels

I just wanted to update this thread. We've got a letter today with another complicated series of tables and calculations over many pages and it looks like it has been looked at afresh for all of the loans and we have a new redress amount.

I was slightly incorrect in my earlier posts when I said they upheld the complaint with the first of 5 loans and how it carried through the subsequent 4 consolidating loans - it transpires that the first didn't have PPI was disregarded from the outset, it was the 2nd of the 5 chronologically that generated the earlier redress - so only 4 were ever considered, I just mis-remembered the letter when I posted here.

I thought that only the latest one would qualify for a Plevin payout on dates, but it looks like an 'unfair relationship' payout on loans 2 and 3 and PPI redress now for loans 4 and 5, minus what we already had, less some claims, so we're now in line for a decent further redress.

As Moneyineptitude suggested earlier in the thread, it looks like it has been totally re-assessed and the new redress is more in line with what it maybe should have been, which is truly a bonus at a time when one is very welcome.