Not upheld: failure to disclose commission complaint against Royal London Mutual Insurance Society, Limited (trading as Scottish Provident)

Decision detail

Summary

Mr G purchased a term assurance policy in 2010 through intermediary firm B and was not informed about commission payments to B. He only discovered the commission arrangement in 2025 and complained to Scottish Provident, arguing it should have disclosed the commission despite B's responsibility to do so. The ombudsman found that regulatory requirements at the time placed disclosure responsibility solely on the advising firm B, not on Scottish Provident as the policy provider. Scottish Provident had no separate obligation to disclose the commission or verify that B had done so, and the commission structure was typical for the period. The complaint was not upheld.

The Ombudsman's reasoning

The regulatory framework at the time placed responsibility for disclosing adviser remuneration on the advising firm (B), not the policy provider (Scottish Provident). Scottish Provident was not involved in selling the policy and therefore did not have the same disclosure requirements. It was reasonable for Scottish Provident to expect B would pass the illustration to Mr G. Scottish Provident had no separate obligation to proactively send additional copies or follow up with B. Commission structures involving initial and ongoing payments were typical and standard practice at the time, and did not constitute unreasonable conduct.

How this compares

Source

Read the original decision on the Financial Ombudsman Service website