Premium Credit Ltd (PCL) has written to insurance brokers saying that, following taking King’s Counsel advice, it will not be imposing any changes to existing customer journeys, and firms should not expect any changes from PCL’s perspective either. This approach differs significantly from other from that recently taken by other premium finance providers (e.g., Close Brothers, PremFina) who have taken steps to introduce mandatory commission disclosures in relation to premium finance, and the gathering of customer consent.
PCL has announced that, over the past few weeks, it has thoroughly reviewed the Court of Appeal motor finance commissions case judgment with its legal advisors, including King’s Counsel, to understand whether any changes to its current commission disclosures are required. As part of this analysis, the sales journeys for motor finance against the premium finance sales journey were compared at every stage. The current level of disclosures made in PCL’s documentation and those made in its partners’ journeys were reviewed from a legal perspective, and the distinguishable differences in our sales practices versus those in motor finance were understood and documented. All of this was compared in detail, with the findings from the motor finance Court of Appeal ruling, and the key differences noted.
The conclusion of this detailed review, confirmed by advice from King’s Counsel, is that PCL’s current disclosures are sufficient given the significant differences in its sales practices and the nature of its disclosures when compared with those in motor finance. Therefore, PCL is not asking its distribution partners to make any changes to existing customer journeys, and firms should not expect any changes from its perspective either.
PCL will continue to monitor developments in the motor finance market closely and will keep firms up to date with any relevant information.