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  • dunstonh
    dunstonh Posts: 121,415 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Combo Breaker
    edited 18 June 2025 at 9:06AM
    Before my diagnosis and claim, I requested the Terms and Conditions twice (in 2022 and again in 2024). Both times, Royal London sent me the wrong document — a “Terms of Acceptance” summary, not the full contract.
    I didn’t know it was the wrong document — because, as a layperson, I’m not expected to. I relied on Royal London’s communication to be clear, accurate, and fair.
    Only after my claim was declined did they finally send the full policy and exclusions — months after I’d specifically asked for it.
    In one email, Royal London even admitted that the T&Cs were “probably never sent, as customers don’t usually request them.” So there’s no dispute that I asked, and that they failed to send them.

    The retailer would have had them available to provide to you at point of sale to download.


    Why this matters:
     This is a clear breach of several FCA rules:
    ICOBS 6.1.5R – firms must provide appropriate, comprehensible, and timely information so the customer can make informed decisions.
    ICOBS 2.2.2R – firms must act honestly, fairly and professionally in accordance with the best interests of their customer.
    FCA Principles 6 & 7 – fair treatment of customers and clear, not misleading communications.
    Consumer Rights Act 2015 (Section 68) – contract terms must be transparent and prominent.
    If I don’t receive the actual T&Cs after specifically asking for them — twice — how could I possibly know what my policy covered or excluded?
    It’s not realistic to expect a customer to spot the difference between an “acceptance letter” and the full legal policy when nothing in the communication says, “This is not your T&Cs.”

    Royal London did not retail the product to you.  So, they are not responsible for the documentation provided at prior to or at point of sale.


    Some posters have said it’s my responsibility to review the market or switch policies. I accept that in part. But the regulator has been clear — especially in guidance like FG16/8 — that firms should review older policies when updates may lead to better outcomes, and communicate that to customers, especially if they remain on now-withdrawn products.
    Whether or not my product is a “closed book” in the technical sense, it is no longer for sale, and Royal London themselves referred to it internally as a “closed product.” There is at least an ethical and fairness-based obligation here, if not a regulatory one.

    As already stated on this thread, that does not apply here.

    A closed product is not the same as a closed book.

    3. My neurodiversity and vulnerable customer considerations
    I have been diagnosed as autistic (ASD). I made the FOS aware of this before their final decision. Despite that, I received no tailored communication, no clarification of how my evidence had been considered, and no adjustments made to ensure I understood the rationale behind the decision — which was confusing and distressing.
    Under the Equality Act 2010 and FCA FG21/1 (Vulnerable Customers), both Royal London and the Ombudsman had duties to consider how my condition might affect my ability to engage in a complex dispute process and to make reasonable adjustments. That didn’t happen.

    None of that applies to point of sale, which Royal London were not involved or any point up to you told them.   It is entirely possible that individual staff members don't have a clue about how they would need to deal with you specifically unless you told them.   These people are not doctors.  They will draw on experience and training which will be to listen and examine your communications.  


    This isn’t about wanting cover I didn’t pay for. It’s about:
    Being misled (however unintentionally) by Royal London’s failure to send the actual terms;
    Being disadvantaged because I wasn’t told about newer policies when mine was no longer sold;
    And then having the FOS accept the insurer’s assumptions over my documented evidence — without explanation — despite my vulnerable status.
    If anyone has had a similar situation or found a solicitor or advocate who understands this kind of regulatory breach and how vulnerable customers are meant to be treated, I’d be grateful for a recommendation.

    You are seeing regulatory breaches where there are none.

    You are expecting a manufacturer to carry out the duties that the retailer is meant to do.  That isn't how it works.  If you had bought the product direct from Royal London, then it would have a duty as a retailer to make the documentation available to you at or prior to sale.   

    If you were paying a company to provide the ongoing services you are after then that company has a duty to you.   However, you bypassed the companies that can do that sort of thing to take on that responsibility yourself.    Royal London does not provide that service and you haven't paid Royal London to provide that service.


    I am an Independent Financial Adviser (IFA). The comments I make are just my opinion and are for discussion purposes only. They are not financial advice and you should not treat them as such. If you feel an area discussed may be relevant to you, then please seek advice from an Independent Financial Adviser local to you.
  • DullGreyGuy
    DullGreyGuy Posts: 18,613 Forumite
    10,000 Posts Second Anniversary Name Dropper
    NotNigel said:

     I understand that critical illness cover is a non-advised product and that terms evolve.

    No product is inherently advised or non-advised, my protection products were all bought on an advised sales basis because I wanted, and felt I needed, the advice of a specialist rather than choosing to go down the non-advised sale route. You had the same choice but decided you wanted non-advised.

    NotNigel said:
    • Being disadvantaged because I wasn’t told about newer policies when mine was no longer sold;

    No matter how many times you repeat it it won't change the reality that they dont have to inform pure insurance customers about new products any more than Apple has to tell you when there is a new iPhone or Barrett when they are putting up a new development of houses.

    It may have been is you had an advisor they would have

    NotNigel said:

    1. Failure to Provide the Contract (Terms and Conditions) – Twice

    You dont say which aggregator you used but there will have been an intermediary that they introduced you to; if you used Money Supermarket, as the owners of this site, for example then its LifeSearch that sold you the policy and its them that should have provided you with the T&Cs.
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