Motor Insurance Price comparison sites ripoff and misleading public

Ergates

the_lunatic_is_in_my_head said:

Ergates said:

the_lunatic_is_in_my_head said:

Hello OP

It's potentially a breach of the Consumer Protection from Unfair Trading Regulations, report via Citizens Advice but be aware enforcement of such things is sadly lacking.  

That would only apply if it was the company offering the contact who presented the inaccurate price.  Go compare isn't that company and isn't acting as an authorised agent on their behalf.

If *I* told you that Currys were selling new 50" TVs for £100, and you went there and saw they weren't, it wouldn't be Currys fault or responsibility.

Which part of the regs are you relying upon to make this statement? I don't see anything that suggests such, the regs mention the actions of traders and how they affect the transactional decision of the consumer (price comparison sites are traders).  

RE second paragraph, you aren't a trader so the regs don't apply.

Go compare aren't a trader - you have no contact with them.

user1977

Ergates said:

the_lunatic_is_in_my_head said:

Hello OP

It's potentially a breach of the Consumer Protection from Unfair Trading Regulations, report via Citizens Advice but be aware enforcement of such things is sadly lacking.  

That would only apply if it was the company offering the contact who presented the inaccurate price.  Go compare isn't that company and isn't acting as an authorised agent on their behalf.

Aren't they? I thought they were providing the prices with the full co-operation (and commission from) the companies they list.

the_lunatic_is_in_my_head

Ergates said:

the_lunatic_is_in_my_head said:

Ergates said:

the_lunatic_is_in_my_head said:

Hello OP

It's potentially a breach of the Consumer Protection from Unfair Trading Regulations, report via Citizens Advice but be aware enforcement of such things is sadly lacking.  

That would only apply if it was the company offering the contact who presented the inaccurate price.  Go compare isn't that company and isn't acting as an authorised agent on their behalf.

If *I* told you that Currys were selling new 50" TVs for £100, and you went there and saw they weren't, it wouldn't be Currys fault or responsibility.

Which part of the regs are you relying upon to make this statement? I don't see anything that suggests such, the regs mention the actions of traders and how they affect the transactional decision of the consumer (price comparison sites are traders).  

RE second paragraph, you aren't a trader so the regs don't apply.

Go compare aren't a trader - you have no contact with them.

Umm, you think they aren't a person (or in this case entity) acting for purposes relating to that person's trade, business, craft or profession  or do you think you need a contract for the CPRs to apply? 

You understand a business, say your example of Currys, can breach the CPRs without forming a contract right? 

DullGreyGuy

the_lunatic_is_in_my_head said:

Ergates said:

the_lunatic_is_in_my_head said:

Hello OP

It's potentially a breach of the Consumer Protection from Unfair Trading Regulations, report via Citizens Advice but be aware enforcement of such things is sadly lacking.  

That would only apply if it was the company offering the contact who presented the inaccurate price.  Go compare isn't that company and isn't acting as an authorised agent on their behalf.

If *I* told you that Currys were selling new 50" TVs for £100, and you went there and saw they weren't, it wouldn't be Currys fault or responsibility.

Which part of the regs are you relying upon to make this statement? I don't see anything that suggests such, the regs mention the actions of traders and how they affect the transactional decision of the consumer (price comparison sites are traders).  

RE second paragraph, you aren't a trader so the regs don't apply.

They're not traders to the consumer as they sell nothing to them, the transaction is conducted on the traders own website (be that insurer, broker, intermediary etc). 

There is a slight difference with non-core products like SME insurance which actually isn't an aggregator at all but just a broker exposing their panel in the way an aggregator does but even then whilst the URL may be business.confused.com the footer will tell you that you are actually dealing with Simply Business and you will be contracting with Simply Business 

the_lunatic_is_in_my_head

DullGreyGuy said:

They're not traders to the consumer as they sell nothing to them, the transaction is conducted on the traders own website (be that insurer, broker, intermediary etc). 

There is a slight difference with non-core products like SME insurance which actually isn't an aggregator at all but just a broker exposing their panel in the way an aggregator does but even then whilst the URL may be business.confused.com the footer will tell you that you are actually dealing with Simply Business and you will be contracting with Simply Business 

And where in the regs does it say they have to be traders to consumers? The regs prohibit misleading actions or omissions within the set criteria if they alter or are likely to alter the transactional decision of the average consumer. 

Lovely sunny day so I can't be bothered to spend much time arguing but the UK Regulators Network disagree with you both:

https://ukrn.org.uk/app/uploads/2018/11/201609027-UKRN-PCWs-Report.pdf

General consumer protection and competition rules applied to PCWs (Price Comparison Websites)

Consumer Protection from Unfair Trading Regulations 2008 (CPRs)6

2.3. The CPRs include a general prohibition of unfair commercial practices,

7 prohibitions of misleading

and aggressive practices,

8 and 31 practices prohibited in all circumstances.9 In some way this leads to

a commonality in standards for PCWs.

2.4. There are some specific regulations contained in the CPRs that are of particular relevance to PCWs.

Regulations 5 and 6 prohibit commercial practices which are misleading (whether by action or

omission) and which cause or are likely to cause the average consumer10 to take a different

transactional decision. This might include, for example:

 if a PCW were to omit material information in relation to the ranking methodology used by it or

the price of the deals it displayed, which causes or is likely to cause the average consumer to take

a different transactional decision; and

 if a PCW were to make misleading claims that caused or are likely to cause the average consumer

to take a different transactional decision in relation to:

 the price of a displayed deal or the manner in which it was calculated;

 the specific price advantage of a deal, for example, where a deal may be displayed higher in a

ranking than a cheaper deal; or

 the market coverage of a PCW.

2.5. The FCA, Ofgem, and Ofcom have the power to enforce the CPRs under Part 8 of the Enterprise

Act 2002 (“the EA02”) if they thought it was appropriate and in line with their respective duties and

functions. For Ofcom and Ofgem, any enforcement action under Part 8 of the EA02 would be

conducted in accordance with their respective Enforcement Guidelines.

11,12 Ofgem, Ofcom and the

FCA need to go to court to enforce the CPRs.

13 In practice, none of these organisations have

brought enforcement cases for potential breaches of the CPRs against PCWs. However, Ofgem has

previously liaised with Trading Standards regarding the ability of Trading Standards to use consumer

protection law against PCWs.

DullGreyGuy

user1977 said:

Ergates said:

the_lunatic_is_in_my_head said:

Hello OP

It's potentially a breach of the Consumer Protection from Unfair Trading Regulations, report via Citizens Advice but be aware enforcement of such things is sadly lacking.  

That would only apply if it was the company offering the contact who presented the inaccurate price.  Go compare isn't that company and isn't acting as an authorised agent on their behalf.

Aren't they? I thought they were providing the prices with the full co-operation (and commission from) the companies they list.

Historically no, Money Supermarket in particular were in a constant cat and mouse game with Direct Line, confused.com had built screen scraping and counter-antibot scripts to be able to quote DL, not only did they not have the consent from DL but DL issued against them multiple times for trademark infringements etc. 

Clearly at the time the kudos of being able to say you were the only comparison site with DL on it was worth the legal costs. Obv any policies sold via such activities were commission free to DL. 


At a later date DLG offered up some of its brands (Priv, Churchill, Tesco at the time) and so relationships changed. Aviva are similar with the core brand not being on there but secondary brands are, though they went the other way of originally being on them and then pulling away. 


Many smaller brands will be on by virtue of the software that they use, they can still tell their software house to turn their brand off from being on the aggregators but its a very different setup than the likes of DLG that had their own in-house developed solutions and direct contracts with the aggregators etc. 

Ergates

Dookdik17095 said:

at very least it is missleading at worse a complet ripoff ,, I have passed this on to BBC and trading standards

There is no benefit to Go Compare of presenting a misleading price from the insurers they display - as they only get paid if the person who clicks through completes the transaction (which is less likely to happen if the prices don't match).

TELLIT01

Dookdik17095 said:

I have spoken with Go Compare customer service but they  blamed the insures .. hmm 

They are absolutely correct in what they have told you.  All any of the comparison sites do is pull information from the provider into a single location.  They have no control over whether the provider keeps the information current or not.

the_lunatic_is_in_my_head

TELLIT01 said:

They have no control over whether the provider keeps the information current or not.

But they do have control over continuing to display such options when informed of an issue. 

Ergates said:

Dookdik17095 said:

at very least it is missleading at worse a complet ripoff ,, I have passed this on to BBC and trading standards

There is no benefit to Go Compare of presenting a misleading price from the insurers they display - as they only get paid if the person who clicks through completes the transaction (which is less likely to happen if the prices don't match).

A cynic might suggest something like this could be done in the hope people either won't notice or having picked an insurer will just continue any way.

There is as much benefit to the to Go Compare as there is to the insurer, i.e it's either a mistake and neither benefit as the consumer abandons/starts again or they both benefit. 

Ergates

the_lunatic_is_in_my_head said:

TELLIT01 said:

They have no control over whether the provider keeps the information current or not.

But they do have control over continuing to display such options when informed of an issue. 

Ergates said:

Dookdik17095 said:

at very least it is missleading at worse a complet ripoff ,, I have passed this on to BBC and trading standards

There is no benefit to Go Compare of presenting a misleading price from the insurers they display - as they only get paid if the person who clicks through completes the transaction (which is less likely to happen if the prices don't match).

A cynic might suggest something like this could be done in the hope people either won't notice or having picked an insurer will just continue any way.

There is as much benefit to the to Go Compare as there is to the insurer, i.e it's either a mistake and neither benefit as the consumer abandons/starts again or they both benefit. 

The problem with cynics is they always assume the worst case without thinking through the long term implications.  

As a deliberate ploy, that might work a couple of times - but not very often.  And when people abandon the transaction they're quite likely to abandon Go Compare altogether (what would be the point in using them if they prices they quote are wrong).  No not only would Go Compare not get that commission, they'd not get *any* commission from that customer ever again.  Moreover, Go Compare get commission from *any* of the insurers they redirect people to - so other than the slightly different rates they'll get from different companies, there is little incentive to prefer one of the other, certainly not to the extent of risking repeat business.

If your business operates by providing information to consumers, and consumers find out that the information you provide is routinely (and/or deliberately) inaccurate you will go out of business.