The Financial Conduct Authority (FCA) will continue to look closely at the impact of premium finance on consumers, particularly vulnerable customers. Insurers and brokers should review their premium finance products, looking particularly at the APRs charged and whether the decision to pay monthly is also factored into the setting of the underlying insurance premium (so-called 'double-dipping'). They should be prepared to justify their approach to the FCA if required and to show that it is objectively justified and reasonable. In addition, the long-awaited overhaul of the UK's fifty year old consumer credit laws has begun, and will eventually result in a more flexible regime, better suited to today's products and sales channels. Firms should engage with this process so they can benefit from all of the expected changes.




