Re the "super complaint" (www.insurancetimes.co.uk, 15 September) lodged with the Office of Fair Trading (OFT) by the Citizen's Advice Bureau (CAB).

As a responsible practitioner in the payment protection market, we welcome any independent review that helps the FSA stamp out the non compliant "fringe" markets and anti-consumer practices that regrettably occur.

We are concerned, however, that this complaint will result in the national media and consumer bodies lumping the good with the bad.

In their haste to highlight the poor practices that continue to blight the industry, they will fail to recognise that there is a genuine need for this type of protection particularly associated with mortgages.

If payment protection products are treated with a 'knee jerk' reaction, the sales of genuinely needed protection policies could reduce and undoubtedly create an increase in mortgage repossessions.

A number of providers of these policies, including Millennium have gone above and beyond the benchmark mortgage cover recommended jointly by the ABI and the Council of Mortgage Lenders to create protection products that do put the consumer first, and stand up to the criticisms of CAB. For example:

  • The cost of protection has come in for criticism, but there are many products available to consumers through financial advisers costing as little as 80p per day for a monthly benefit worth £500
  • These consumer-friendly policies cover medical problems such as bad backs and mental illness - two of the exclusions highlighted by the CAB in its complaint - so long as the claimant has medical evidence (such as an MRI scan or a consultant diagnosis). This is hardly an excessive demand by insurers who have been subjected to extensive fraud in these two areas.
  • The regulator, insurers, providers and distributors of these products must come together and create a framework that stamps out non-compliant practice and puts the customer at the heart of the product and service delivered.

    And insurers and providers must redouble their efforts to ensure that advisers understand what they are offering and, more importantly, customers know what they are buying.

    Better awareness and better training are called for, not the destruction of the product itself.

    Steve Clowes
    Managing director
    Millennium Insurance

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