Consumer Wordings Guidance v4.2
The latest version of the Joint LMA/Clyde & Co Guidance on Consumer Wordings is available to download from the LMA website, and contains a Document Revision/Change History page to identify the key amendments/updates.
The updated guidance includes the following:
- Introduction – placeholders added to (i) note that Lloyd’s Minimum Standards are changing from 01 January 2019 - MS11 will be replaced by the new MS9 Standard and (ii) the range of customers which will be able to refer complaints to the FOS is changing with effect from 01 April 2019.
- Complaints – updated to include FCA Handbook definition of a 'complaint' and reference to Market Bulletin Y5200.
- Updated example Financial Services Compensation Scheme (FSCS) clause added (LMA9125A) to reflect current FSCS address.
• Other Documentation - Insurance Product Information Documents (IPIDs) and Policy Summaries updated to reflect IDD implementation on 01 October 2018.
- Updates to Appendices 1, 2, 8, 11, 14 and 15.
At the time of its initial publication (version 1.0, 27 April 2015), we advised that the guidance would undergo a periodic review process by the LMA and, therefore, remain subject to amendment/update when required (e.g. due to change/update in relevant legislation/regulation etc.). The guidance was re-published on 14 February 2018 (v4.0) to include updates on GDPR and the IDD and again on 18 June 2018 (v4.1) to provide further GDPR updates.
The document is published as general guidance, intended to assist managing agents with the practicalities of drafting new consumer products and/or adapting existing commercial wordings to produce consumer versions. Whilst not an exhaustive list of all the issues to consider, the guidance identifies the key features of, and salient clauses within, a policy document/wording that need to be addressed for a consumer policy to meet current regulatory requirements and identifies, where appropriate, the applicable underlying regulation. Example clauses are also provided, where applicable.
Any queries on the guidance may be addressed to:
Head of Regulatory Affairs
Head of Wordings