From my early days leading the handling of insurance disputes at FOS I saw complaints about the price of insurance premiums. At the time, neither the industry nor the ombudsman had much sympathy with the consumer's position, feeling that in an open and competitive market the consumer was free to decline cover and shop around if they felt the price they were being offered was too expensive.

But it was clear that many, for whatever reason, had become stuck in a cycle of renewal and were paying far more for their cover than they would have if they had changed insurer.

We set about investigating what was fair in the world of insurance premium pricing and I spent a number of years leading staff investigating all types of pricing disputes, talking to insurers and consumers, and creating decision making policy on the issue.

The CAB super complaint has dropped a large stone in the pond and the ripples are still being assessed by the FCA. But what's clear is that regulatory oversight is firmly focussed on the issue and change is expected in the industry. In its preliminary findings the FCA has challenged insurers to rethink their regulatory requirements to treat customers fairly and expects consumer fairness to be a key focus at senior leadership levels.

While the focus of the super complaint was the concept of a "loyalty penalty" - or market "inertia" as we called it at FOS - I've seen first hand that issues of unfairness arise in many other aspects of insurers' price setting models and operational practices. In some instance it's clear that there are cultural issues throughout the consumer pricing journey, and beyond, which have been impacted by macro economic models that, as the FCA confirms, have lost sight of the insurer's wider responsibilities. 

Undoubtedly pricing models are going to need to change but the necessary changes will, for some, have major ramifications, affecting overall business strategy and marketing and the relationship with intermediaries of all types. And those changes will need to be reflected in cultural change programmes as much as in operational structure and strategy.

With more than 20 years as a senior operational leader, and over 6 years in insurance dispute leadership at the FOS, I have the experience and skills to help.

I'd be delighted to have a preliminary conversation with you to help in your planning and to consider how I'm able to provide support with:

      -    understanding the ombudsman's approach to pricing fairness

      -    understanding regulatory requirements

      -    identifying change requirements throughout the consumer experience

      -    delivering operational change projects

      -    interpreting what "fairness" looks like and how to deliver it, including cultural change

      -    visualising and designing strategic change with fairness in mind

      -    meeting the regulators expectation of embedding "fairness" at senior levels

      -    dispute resolution on complex cases needing expert input

      -    ensuring complaints handling meets regulatory objectives

      -    making the most of complaints as part of a quality assurance model to drive improvements    

Please feel free to contact me by telephone or e mail to discuss your needs.

John Withington