Lloyd's Market Association Bulletin

LMA19-013-AC  |  29 March 2019

Consumer Wordings Guidance v5.0
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.

Consumer Wordings Guidance v.5.0

The updated guidance includes: 

  • Changes throughout the document to reflect that Lloyd’s Minimum Standards changed from 01 January 2019 - MS11 has been replaced by the new MS9 Customer Standard. 
  • Reference to the FCA’s Finalised Guidance (FG18/7) entitled “Fairness of variation terms in financial services consumer contracts under the Consumer Rights Act 2015”) has been added in various places, notably under Appendix 10.
  • Updates to Appendices 1, 2, 5, 9 and 10.

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. Version v4.2 of the guidance was published on 28 November 2018, which included, amongst other things, updates in respect of Insurance Product Information Documents (IPIDs) requirements.

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:

 Lloyd's Market Association Clyde & Co LLP 
 Alison Colver
 Ian Plumley
 Head of Wordings  Partner
 alison.colver@lmalloyds.com  ian.plumley@clydeco.com
 Steve Morrell  
 Head of Regulatory Affairs  

Alison Colver
Head of Wordings