Financial Services Authority

Consultation Paper 04/12
FSMA 2 Year Review: Financial Ombudsman Service July 2004

Questionnaire

July 2004

The FSA would welcome comments on this consultation paper. Comments should reach us by 1 October 2004. You can send your response by electronic submission using the following form

If you wish to respond by letter, please send your response to the following

Lisa Wrigley, FSA and Tony King, FOS
Ombudsman Stakeholder Review Secretariat
c/o Retail Themes Division
25 The North Colonnade
Canary Wharf
London
E14 5HS

Email: responses@ombudsman-review.org.uk

It is the FSA's policy to make all responses to formal consultation available for public inspection unless the respondent requests otherwise


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Q1 Why is the wider implications process seldom used? Is it because there are few wider implications cases, because they are difficult to identify, or some other reason? Where wider implications cases are identified, does this happen early enough? If not, how could they be identified earlier?


Q2 Does this clarify the circumstances in which FSA believes it should consider a wider implications referral? If not, what remains unclear? Are there other criteria FSA should consider? Is the proposed approach here likely to be too narrow? If so what cases would this rule out that would cause difficulty? Should FSA take a different approach? If so, why?


Q3 Does this clarify who can (and who should) identify wider implications cases? Would the proposal for nominated individuals facilitate this? Are there any practical barriers that need to be overcome?


Q4 Would these changes improve the wider implications arrangements between FSA and FOS? If not, what changes would you propose? Should the information be provided more widely than to industry and consumer bodies? Should it be summarised in FSA’s annual report and/or on its website?


Q5 Is such a process for channelling contextual information to FOS needed? If so, is anything further needed? In what circumstances would the process be useful? Would it enable FOS to make a better informed decision? Would it affect public perception of FOS’s independence? Would it be fair to the parties to the case?


Q6 Is there a role for the Industry Liaison Groups, and what changes to their terms of reference would be needed? Do consumer groups prefer their existing bilateral arrangements with FOS, or is there a role for a Consumer Liaison Group? Alternatively, should there be a special panel, with industry and consumer members?


Q7 In what circumstances would a test case be helpful? What would be the advantages and disadvantages? Should FOS issue guidelines about the circumstances in which it would consider a test case approach?


Q8 If the wider implications process is improved, as proposed in Chapters 3 and 4, is an appeal mechanism needed? If so, why? Has anything relevant changed since FSMA was passed? Is the problem simply that firms do not like some case outcomes? If not, what specific problems would an appeal mechanism solve?


Q9 Do firms want appeals? Do consumers want appeals? If so – for what types of cases, why and to whom? How would it be decided how many cases, and which ones, should go to appeal? How often might an appeals body reach a different conclusion from the ombudsman, and why? Should the appeal decision apply to other consumers?


 
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