Covid-19 (coronavirus)

Section 75 complaints 

With section 75 complaints, the things we’ll look at in particular include the following:

• When deciding what’s fair and reasonable, we’ll always consider individual circumstances. 
• We expect card issuers to consider chargeback and section 75 claims where appropriate, regardless of how the consumer expressed their claim.
• We expect businesses to consider whether they should pay any consequential losses. 
• We’ll take into account whether consumers have already been able to recover financial losses from the suppliers. 
• We expect businesses to treat consumers in financial difficulty positively and sympathetically.

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

Financial difficulties 

When handling a complaint about financial difficulty, the things we’ll look at in particular include the following:

• When deciding what’s fair and reasonable, we’ll always consider individual circumstances. 
• We expect businesses to treat consumers in financial difficulty positively and sympathetically, fairly and with forbearance – in line with FCA’s principles and rules (set out in the Consumer Credit Sourcebook (CONC)).
• We expect businesses to listen to consumers and proactively look for signs of financial difficulties. Consumers may not always know the best way to express their concerns. 
• If a consumer is facing financial difficulty, we expect businesses to consider forbearance measures such as token repayment plans, freezing interest and charges, reasonable arrears rescheduling and debt write-off where appropriate.

• Given the extraordinary circumstances, we may expect businesses to think about additional forbearance measures alongside the above, such as payment freezes, and have regard to the temporary measures introduced by the FCA in April 2020 and July 2020, and the finalised guidance introduced in October 2020. These are designed to provide temporary or longer term tailored financial relief for customers affected by Covid-19 on products such as credit cards, loans and overdrafts.

• The FCA also confirmed targeted temporary measures to cover motor finance and high-cost credit agreements in April 2020 and July 2020, which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking. The finalised guidance is relevant to some of these products also.
• We’ve issued specific guidance on this page for people having difficulty with their mortgage payments or car finance.

Read more about our approach to complaints from consumers who are in financial difficulties.

Car finance – and other hire purchase/conditional sale/lease/hire agreements

The things we’ll look at in particular, include the following:

• When deciding what’s fair and reasonable, we’ll always consider the individual circumstances.
• We expect businesses to listen and proactively look for signs of financial difficulty. Please refer to our guidance on financial difficulty above. 

• Given the extraordinary circumstances, we expect businesses to be even more flexible in their forbearance measures, as set out above. We’d also expect them to consider the specific needs of an individual to stay mobile at this time. The FCA confirmed targeted temporary measures to cover finance and high-cost credit agreements in April 2020 and July 2020 which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking. It released finalised guidance in October 2020. 

• We expect businesses to fully inform consumers of their options to exit the agreement where necessary or appropriate. Different exit options result in different liabilities for consumers. Businesses should give them a clear explanation of the different options. This is to allow consumers to understand fully the implications on the amount which would remain outstanding on their loan under each of the termination options. Businesses should also alert consumers to any impact this may have on their credit file.
• We remind businesses that reporting to credit reference agencies should not only be accurate but also fair in the circumstances.
• If there is a dispute about the quality of the goods, and where the normal ways of inspecting the goods aren’t available, we’d expect businesses to be flexible and use initiative in trying to resolve complaints.

Read more about our approach to complaints about car finance. 

The FCA has set out information for insurers during the pandemic. 

Travel insurance 

The things we’ll look at in particular, include the following:

• We’ll always consider individual circumstances including the relevant policy terms, when bookings were made and when the policy was taken out.
• We’ll take into account whether consumers have already been able to recover financial losses from their airline, tour operator, bank or credit card company.
• We’ll consider foreign and domestic government information about travel restrictions in the same way as the FCDO advice, taking account of policy terms.
• We’ll consider self-isolation and cancellations due to sickness in the same way as we do with ‘travelling against medical advice’.
• We expect insurers to take a pragmatic view of decisions not to travel or to curtail a trip. We’ll bear in mind factors such as the purpose of travel, the rapid pace of changing advice and the ability of consumers to contact their insurer at the relevant time.
• We recognise the challenges of validating some claims. However, we expect consumers to be treated fairly, and we encourage insurers to consider carefully the available evidence including credible consumer testimony.

• We recognise that some consumers may have taken the difficult decision to cancel their trips earlier than insurers might usually expect. But insurers should consider whether a later claim would have been accepted – for example, if travel advice or restrictions would have meant the consumer would have ultimately had to cancel before departure date.

Read more about our approach to complaints about travel insurance.

Business interruption (protection) insurance

For information about how we handle complaints about business interruption insurance, take a look at our separate page on our small business website.

Wedding insurance

For guidance specifically on wedding insurance, please look at our dedicated page for businesses that contains information about how we deal with complaints about wedding insurance, including complaints about Covid-19.