Covid-19 (coronavirus)

Guidance about specific types of complaint

• If you're experiencing financial difficulties

  If you’re struggling to make payment to any of your credit commitments, you should contact your creditor as soon as possible to let them know. Your creditor should listen to you and treat you fairly. There are rules and approaches they’re expected to follow to help you.

  The FCA has confirmed a range of targeted temporary measures in April 2020 and July 2020 designed to provide temporary financial relief for consumers impacted by Covid-19. These include the offer of a temporary payment freeze for up to three months on some products, such as credit cards, loans and overdrafts, without your credit file being negatively impacted. In addition, there are measures around overdraft interest and pricing. We’d expect credit providers to look carefully at your circumstances and respond positively if you are in financial difficulties and to consider whether other forbearance measures are suitable. Consumers should check their financial business's websites or social media posts for more information, and where possible use online services to request assistance.

  The FCA announced targeted temporary measures to support motor finance consumers facing payment difficulties due to Covid-19. These include the offer of a temporary payment freeze for up to three months without your credit file being negatively impacted. The measures also offer guidance for consumers who may be approaching the end of an agreement and are struggling to meet any balloon payment due to Covid-19 related payment difficulties.

  The measures also cover high cost credit agreements, which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking. These include a one month payment freeze for high-cost short-term credit, with no additional interest to be charged to the customer as a result of the payment freeze. The measures also include a three month payment freeze for consumers who have entered into BNPL, RTO or pawnbroking agreements.

  The FCA announced finalised guidance for firms in respect of certain consumer credit agreements and overdrafts in October 2020. The measure apply both to consumers who have benefitted from support under the temporary measures in place until 31 October 2020 and continue to face financial difficulties, as well as those whose financial situation may be newly affected by coronavirus after 31 October 2020. 

  The guidance includes an expectation that firms will: 

  • provide tailored support which reflects customer's individual circumstances.
  • work with customers approaching the end of a payment deferral to provide support before they miss payments. 
  • be flexible and employ a full range of shorter and longer-term options to support their customers and minimise stress and anxiety experienced by customers in financial difficulty. 
  • give customers time and opportunity to repay and do not pressurise them into repaying their debt within an unreasonably short period of time. 
  • put in place sustainable repayment arrangements which are affordable and take account of their customers' wider financial situation including their other debts and essential living expenses. 
  • prevent customers' balances from escalating once they have put in place a repayment arrangement by suspending, reducing, waiving or cancelling any interest, fees or charges necessary to make that happen. 
  • recognise and respond to the needs of vulnerable customers. 

  You can read the latest information for consumers on personal loans, credit cards, overdrafts, motor finance and other forms of credit on the FCA's website.

  Find out more about our general approach to complaints around financial difficulties

• If you're worried about your mortgage payments

  We would always expect a mortgage lender to help people who are experiencing financial difficulties. The industry regulator, the Financial Conduct Authority (FCA), has issued guidance to mortgage lenders setting out how they should be dealing with people who may be experiencing financial difficulty and are struggling to make their mortgage payments. You can read more information for consumers about mortgages and Covid-19 on the FCA's website.

  • The FCA has explained that a payment holiday may be a way to help many people in this particular time. A ‘payment holiday’ means a lender allows a customer to make no payments towards their mortgage for a specific time period without being treated as if they are in mortgage arrears. And at this time, it will not have an effect on their credit file. Lenders should not be applying fees and charges for this, although interest will still be applied in most cases.
  • If you are in a situation where you are experiencing difficulties in the current circumstances and wish to apply for a payment holiday, then all mortgage lenders should agree to this for at least the next three months payments following you contacting them. Anyone who is currently worried about maintaining their mortgage payments during this time, including buy-to-let customers, should get in touch with their lender at the earliest possible opportunity to discuss how they can help. This also applies to anyone who is already in mortgage arrears or has a payment arrangement in place. Your lender should explain the full implications to you of a payment holiday. Of course lenders can explore other options which may be more suitable for customers including longer payment holidays if that might be better for you.
  • Lenders have also been told they should not start or continue with any repossession action at this time given the government requiring us to stay at home. And if a possession order has been obtained, lenders should not be enforcing this. If you are currently in any of these situations, please contact your lender to discuss your options.
  • Given the stay at home advice, if you are currently moving house, or changing mortgages, then you should contact your mortgage lender, mortgage broker or estate agent to discuss the situation.
  • The Bank of England has reduced rates due to the current economic situation caused by Covid-19 to an historic low. Some lenders have already passed on reductions to its customers, with others due to make decisions and announcements shortly. If you have any questions about how this may affect your mortgage, look on your lender's website, or contact them directly.
  • At this stage, the most important thing to do is speak with your lender at the earliest opportunity. Your lender may be more difficult than usual to contact by phone, but many lenders are making the option to apply for a payment holiday available online, though if you don’t think that’s the right option, you might need to keep trying to get through.
  • If you are unhappy with what you lender tells you, we may be able to help. But we hope that most people will be able to resolve issues with their lender directly, and that lenders will be helping where possible due to the current situation.

  Find out more about our general approach to complaints about financial difficulties

• Goods and services paid for with a credit card or by finance agreement

  When something has gone wrong with the supply of goods or services, your credit provider or card issuer can help you under certain circumstances. So if you’ve paid for things like goods that haven’t arrived or a service that hasn’t been provided, your creditor/card issuer might be able to help.

  Depending on how you paid for the goods or services, credit providers can look at these types of claims under processes known as "section 75" or "chargeback". Or for finance agreements like hire purchase, the finance company as the supplier of goods or services is responsible when things go wrong.

  There are time limits that apply when raising a chargeback with your bank. So if you are in continued negotiation with a supplier to obtain a refund, you should check with your bank as to any time limits that might apply.

  If you are unhappy with the way your credit or finance provider has handled things, you can make a complaint. You’ll need to contact them first and then wait until either 8 weeks has passed or they’ve issued a final response letter.

  Read more about our approach to complaints about car finance.

  Read more about our general approach to complaints about goods and services bought with credit

• Fraud and scams

  Watch out for scams related to Covid-19. These scams may take many forms and could be about insurance policies, pensions transfers, or high-return investment opportunities, including investments in cryptoassets.

  Scammers are now also pretending to be from local councils and government bodies. Often through text messages with links asking you to pay a fine, or to find out more about Covid-19.

  Scammers are sophisticated and opportunistic. They are also very likely to target people who may be more vulnerable.

  To help protect yourself you should:

  • Beware of offers that appear to be too good be true. 
  • Beware of adverts on social media channels and paid for/sponsored adverts online.
  • Do not click links in text messages or open emails from senders you don't already know.
  • Check email addresses. Often, if it is a scam, the email address the message has come from will be filled in with random numbers, or be misspelled. If you are dealing with a retailer, supplier or merchant always call them on the confirmed genuine number rather than replying to an email or text correspondence as this can be intercepted by fraudsters pretending to be someone genuine.
  • Avoid being rushed or pressured into making a decision.
  • Beware of contact from people saying they are from government or official bodies asking for payments. If someone from an organisation calls you unexpectedly, feel comfortable in saying you’ll call them back from a number on their official website.
  • Do not give out personal details (bank details, address, existing insurance/pensions/investment details).
  • Use the FCA Register and Warning List to check who you are dealing with.
  • If you aren't sure whether something is genuine, check in with a friend or relative before agreeing to anything. 

  Find out more about our general approach to complaints about fraud and scams

• Business interruption (protection) insurance

  You can find detailed information about how we can help with complaints about business interruption insurance on our small business website. 

• Travel insurance

  Cancelled flights and holidays

  You should contact your travel provider, tour operator and/or airline to discuss the current situation on travel or to raise claims for cancelled flights or trips. ABTA and the Civil Aviation Authority have published information for customers, passengers and holidaymakers. 

  If you have booked a package holiday you are entitled to a full refund from your travel provider under the Package Travel Regulations 2018 in certain circumstances. We are aware that some travel providers have encouraged consumers to claim on their insurance policies and have refused to issue refunds to consumers. The Competitions and Markets Authority wrote an open letter to the travel industry in relation to this.

  Before complaining we’d encourage consumers to:

  • Ask the travel provider for a refund
  • Make reasonable attempts to obtain a refund/voucher from their package holiday provider
  • Ask the package holiday provider to confirm, in writing, why they don’t consider a refund can be provided under the Package Travel Regulations
  • If the travel provider is ABTA registered to follow the relevant guidance on ABTA’s website

  Premiums and Refunds

  We understand consumers might feel their single or annual multi-trip travel insurance policy is of little use to them due to the impact of Covid-19 – in particular if a holiday has been cancelled or if consumers have no plans to travel again in the immediate future.

  However, a travel insurer carries the risk of a holiday cancellation claim being made from when a travel insurance policy starts. So, a consumer may already had the benefit of some cover under the policy, whether or not they travelled.

  This means we’re unlikely to recommend that consumers should be provided with a full refund of the policy premiums paid in situations where cover under the policy had already started.  

  Many travel insurers are offering consumers a partial pro-rata refund for their annual or single trip holidays. This is usually in the form of a voucher or a cash refund.  

  This usually means that the insurer is going beyond what they are required to do by the relevant industry guidelines and the policy terms and conditions.

  Where we think an insurer has offered a fair refund we’re likely to conclude that the insurer has acted reasonably. Where insurers have offered a voucher, rather than cash, we usually think that’s fair and reasonable provided that the terms of the voucher aren’t unreasonable or restrictive. However, we will always take into account the consumer’s individual circumstances.

  Future travel

  We can't advise whether you can or should book a new trip, cancel a future trip, or give you general travel advice. You should check the latest government advice for guidance.

  Read more about our approach to complaints about travel insurance

• Wedding insurance

  You can find detailed information about our approach to complaints about wedding insurance, including complaints involving Covid-19 in the consumer section of our website.

• Investments and pensions

  We know this will be a worrying time for consumers with investments and pensions – whether they’re concerned about the risk of potential scams and how to avoid them, or about the performance of the money they have invested. And firms who give advice, or manage customers’ investments, will also want to make sure they’re providing the appropriate support for their customers at this time.

  The FCA has reminded firms about what information they can provide their customers with to help them make the right decisions at this time about their investments. We’ll take this into account – alongside other considerations regarding the type of sale and suitability of advice – when deciding whether a firm has acted fairly.