PIMFA Response to FCA CP23/24: Capital Deduction for Redress

PIMFA Consultation Response to FCA CP23/24: Capital Deduction for Redress. We are broadly supportive of the intent behind the CP23/24 as we have long advocated for a ‘polluter pays’ model for the compensation of consumers who have received poor outcomes. However, whilst the proposals appear positive in principle, our members have raised several concerns relating to their application and effectiveness. These are divided into three areas: The practical difficulty in assessing prospective redress liabilities; The possible effects on the PII market and unintended consequences; and Effectiveness to identify, supervise and enforce against bad actors