ACSO recently submitted a response to the HM Treasury (HMT) consultation on the ban on cold calling for consumer financial services and products. This seeks to protect consumers and prevent fraud while increasing trust and confidence in financial services and products, as well as removing pressurised sales tactics.
ACSO broadly supports any proposal which seek to protect the consumer and prevent fraud of any kind, the cost of which is always borne by consumers as a whole, whether directly as victims of such crime or indirectly through higher insurance or other costs or through an increased tax burden. We would also support any measures which can increase consumer confidence in both financial products and services and in the Financial Conduct Authority’s effective and proportionate regulation of those organisations providing them.
However, there is concern that the proposals are somewhat late, with the practice being in decline given the ability for consumers to opt out under the Telephone Preference Service, the decline in landline telephones and the increase in fines from the Information Commissioner’s Office to companies making illegal, unwanted marketing calls. Furthermore, we would expect all service providers to be able to contact their product holders subject to the necessary consents, ensuring vulnerable customers, who are less technologically adept, still have access to the best products on the market. Any removal of this could have a disproportionate impact on vulnerable consumers in particular.
In terms of both public awareness and clarity, ACSO suggests there is a need to be focussed on an effective communication plan, targeting in particular those who could benefit most from the ban. We also suggest simplicity is key to ensure consumers are aware of and protected by any new legislation.
ACSO looks forward to HMT’s response.
The consultation can be found at: https://www.gov.uk/government/consultations/ban-on-cold-calling-for-consumer-financial-services-and-products