PPI LoA Principles – FAQs

Q – Is there a template of what the banks want in a standard LOA?

A – While some LoA formats might be easier to operationalise, it is not the intention of the Principles to impose a specific template for PPI LoAs. Examples of LoAs which align with the Principles may be viewed here. For the period between 1 April 2016 and 1 July 2016 lenders will be aligning feedback on any LoA template examples through the BBA.

Q – Can you confirm that a brand will accept one Letter of Authority (LOA) for multiple products on the one letter of authority provided they are signed by the appropriate person(s)?

A – A brand (as outlined in Annex 2) will accept one LOA for multiple products provided all other principles are also met. If the LOA is in relation to more than one product, each product needs to be specified. ‘Other’ is not a valid product field.

Q – Do we need account details at pre-submission (request for information) stage?

A – Wherever known, account numbers should be included at request for information.

Q – If on return of a DSAR enquiry we wish to submit a complaint on behalf of our mutual client we will be sending a product specific letter of authority. How much detail on the product would need to be present on the LoA. For instance would Mortgage, Loan or credit card be sufficient or would we need the actual product, for instance Barclaycard Visa?

A – DSAR requests are excluded from the PPI LOA Principles and will continue to be served as per current processes. The LOA should include as much detail as possible on the specific product for which a customer has authorised you to raise a complaint. Annex 2 indicates which brands are captured by each lender group. The brand and type of product both need to be referenced on the LOA.

Q – Could you confirm whether you will actually be making any changes to policy and, if so, when you will be communicating this to CMCs?

A – The PPI LOA Principles were communicated to CMCs in February 2016 via the MoJ Bulletin. A number of lender groups have made changes in policy to adhere to the Principles and these will be implemented in April 2016.

Q – The statement of principles requires the CMC contact details including CRM number. We currently have this on the reverse of our LOA- and as you accept copies this information isn’t visible. Will you require this information to be visible on the front of the LOA?

A – Lenders would require CRM numbers to be visible on the first page of an LOA.

Q – Will you require a separate LOA per brand, per product? Or will you require the client to specify exactly which products?

A – The Principles require a brand specific LOA (see Annex 2 on which brands are included in the same lender group) which can be multiproduct so long as the specific products concerned are named. ‘Other’ is not a valid product field.

Q – Will you require a different style LOA, including the customer declaration, for a letter of complaint as compared to a DSAR/PIR/pre-submission request?

A – DSAR requests are excluded from the PPI LOA Principles and will continue to be served as per current processes. The same LOA (adhering to the Principles) can be used both for pre-submission enquiries and raising a complaint.

Q – Will you be changing your policy regarding for how long an LOA remains valid?

A – The Principle on Validity outlines how long an LOA will remain valid for. This may or may not involve changes in policy for some of the lender groups who have signed up to the Principles.

Q – Will you insist on all alterations being signed in full? (we sometimes add extra CAG information to the LOA if the client hasn’t completed it in full- for example a date of birth, a previous name or a previous address. Currently, as long as the change doesn’t materially alter the permission being granted, we don’t return the document to the client so they can sign the alterations)

A – Missing information from the information required by the Principles is material. All changes to the document need to be signed. Information including previous addresses and account numbers are all part of the verification criteria and as such need to be confirmed by/with the customer.

Q – Is there any additional information you will require from April that you don’t currently need?

A – We will require all information outlined in the PPI LOA Principles as a minimum.

Q – If you will be introducing changes, how will you approach LOAs signed prior to April/sent to clients prior to April- will there be a ‘grace period’?

A – LoAs submitted prior to 1 April 2016 will be treated as per the applicable process at that time. From 1 July 2016 lenders would expect all PPI LoAs to be templated/incorporate all the PPI LoA Principles and be signed and dated from 1 April 2016 onwards by customers. For the period between 1 April 2016 and 1 July 2016 lenders will be looking to facilitate the transition of your LoAs to a template that satisfies all of the Principles.

Q – The principles state that the LOA must contain signatures of all account holders. Does this therefore mean that with regard to LOAs for letters of complaint for PPI that any joint account must have one LOA which contains the signatures of all account holders? Will multiple single LOAs (one for each account holder) no longer be acceptable?

A – The LOA must contain signatures of all account holders wishing to make an enquiry or wishing to raise a complaint in relation to a specific product or products. Please refer to Annex two for individual lender policies. If only one account holder wishes to make an enquiry or complain, then only that account holder’s signature is required. If due to their personal circumstances complainants’ signatures cannot all be provided on the same LoA, lenders will accept more than one singly signed LoAs including the same information and submitted together, on the same date.

Q – Would we be correct in thinking that the LOA for a DSAR would always be a single signed LOA (no joint LOA) as a DSAR is for an individual person and that this principle would not affect those LOAs?

A – The PPI LOA Principles exclude DSAR requests which will continue to be served as per current processes.

Q – Would an LOA that has tick boxes regarding the product i.e. a loan, credit card, mortgage, then another set of tick boxes for joint application or singular application comply with the Principles?

A – Tick boxes to indicate product(s) and/or type(S) of account on LOAs would be acceptable in order to satisfy that Principle.

Q – Our letters of authority cover the majority of the suggested principles, with the main exceptions being any client’s previous names or addresses. We currently send out an additional information sheet which has space for the clients to complete any previous names or addresses. If our additional information sheet has the client’s signature and date of signature on there and was sent with the letter of authority, would this be acceptable?

A – The Principles outline the minimum information required on a PPI LoA. Missing information from the information required by the Principles is material.