FPCOB 9 Annex 1 Funeral plan summary

1

What information needs to be contained in the funeral plan summary?

1.1

R

The funeral plan summary must contain the following information:

(1)

a summary of the significant features of the funeral plan;

(2)

a summary of the main exclusions or limitations of the funeral plan;

(3)

an explanation of whether changes can be made to the funeral plan, and if so, the process and any related costs;

(4)

price and payment information;

(5)

the consequences of non-payment;

(6)

the existence and duration of the right of cancellation;

(7)

how to complain to the firm and that complaints may subsequently be referred to the Financial Ombudsman Service;

(8)

details on whether compensation is available from the compensation scheme, if the firm cannot meet its liabilities.

1.2

G

A firm, when providing the information in the funeral plan summary, should consider:

(1)

the rules and guidance on: providing appropriate information to customers in FPCOB 9.2, post contractual changes in FPCOB 9.3 and price information in FPCOB 9.2;

(2)

the order of the information and priority of the information to be provided;

(3)

the information needs of the firm’s typical customer for the funeral plan;

(4)

using colours, images and other ways to make the document more accessible, easy-to-read, and eye-catching; and

(5)

whether to provide additional information to the customer, for example, to assist the customer’s understanding of the proposed arrangements. If a firm does provide additional information, the additional information should not disguise, diminish or obscure important information contained in the funeral plan summary document.

Name and company logo of the funeral plan provider

1.3

R

(1)

The name of the funeral plan provider, its statutory status (GEN 4 Annex 1R) and its firm reference number should follow the title ‘Funeral Plan summary document’ at the top of the first page.

(2)

The provider may insert its company logo to the right of the title.

Purpose of the document and reference to complete pre-contractual and contractual information

1.4

R

The funeral plan summary should state the purpose of the document and that complete pre-contractual and contractual information about the funeral plan is provided to the customer in other documents. The following wording should be used and placed immediately below the name of the provider in a way that it is likely to maximise customers’ awareness that it is a summary only:

This document explains what is and is not included in your funeral plan, how you will pay for your plan and information on cancelling your plan, making a complaint and your entitlement to compensation. Please ensure you read this carefully. Please note this is a summary of your plan; please refer to our pre-contractual documentation and terms & conditions or contact us using the contact details below for further details.

2

How must the summary be presented and formatted?

2.1

R

The funeral plan summary must:

(1)

be a short and standalone document;

(2)

be presented and laid out in a way that is clear and easy to read, using characters of a readable size; and

(3)

be no less comprehensible in the event that, having been originally produced in colour, it is printed or photocopied in black and white.

Length

2.2

R

The summary document must be set out on no more than two sides of A4-sized paper when printed.

Plain language

2.3

The funeral plan summary must be drafted in plain language, facilitating the customer’s understanding of the content of that document, and must focus on key information which the customer needs to make an informed decision. Jargon must be avoided.

Presentation

2.4

G

A firm, when providing the information in the funeral plan summary, should consider:

(1)

the use of tables to display costs and other ways to make the document and information more accessible and easy-to-read; and

(2)

the use of bold and italic text to highlight key information.

Headings, corresponding information and order of content

2.5

R

The subheadings must be in this sequence and have the following corresponding information:

(1)

‘What products and services are included in my funeral plan?’

This section should clearly set out using green tick boxes and text the key products and services the funeral plan provides.

(2)

‘What products and services are not included in my funeral plan?’

This section should clearly set out through red cross boxes and red text the key products and services the funeral plan would not provide that the customer would typically expect to be included in their funeral (e.g. catering, flowers). A firm should also highlight where the cost of a feature (e.g. burial plot) may exceed the allocated allowance.

This section should also clearly set out any additional costs the customer may face (e.g. the need to appoint a new funeral services provider due to the covered individual’s change of address).

If applicable, a firm should prominently state that other exclusions will apply and explain where to find relevant information.

(3)

‘How do I make changes to my plan?’

This section should set out if a customer can make changes to their plan, how they can do so and any related costs. It should also refer to the cancellation process should their needs change.

(4)

‘When and how do I pay?’

A firm should set out the payment options on offer and the timings of these payments. For example, whether payment is in monthly instalments or a lump sum/single payment.

A firm should set out clearly and prominently if the cost of the plan will increase as a result of paying with a different payment option and if so, the cost of each payment option. If applicable, a firm should clearly state the moratorium period in which the funeral will not be provided if the covered individual dies.

A firm should set out clearly and prominently any fees which are, or may be, payable (including the circumstances in which they are payable).

A firm should clearly set out where a customer can find additional information.

(5)

‘What happens if I miss a payment?’

This section should clearly set out any impact of missing payments, including any fees or potential cancellation.

A firm should clearly pinpoint where a customer can find additional information.

(6)

‘How do I cancel my plan?’

A firm should set out the customer’s right to cancel – including how long they have to cancel without incurring a cancellation fee.

A firm should set out clearly and prominently any cancellation fee.

A firm should clearly pinpoint where a customer can find additional information.

(7)

‘How do I make a complaint?’

A customer should complain to the firm in the first instance. The firm should provide information regarding its internal procedures for the reasonable and prompt handling of complaints.

If the customer is unhappy with the firm’s response, they may be able to refer the matter to the Financial Ombudsman Service.

(8)

‘Financial Services Compensation Scheme’

A firm should explain that if it is unable to meet its liabilities, the customer or covered individual (or their estate, if the customer or covered individual has died) may be entitled to compensation from the compensation scheme.

A firm should clearly state where customers and covered individuals can find further information in relation to the compensation scheme.

2(9)

Information concerning potential funeral plan provider failure’

A firm should briefly explain the arrangements in place to ensure that in the event of its failure:

(a)

there will be a reasonable likelihood that the relevant funeral plan contracts will continue to be carried out by another firm, identifying particular terms in its contracts with customers, including relating to prior consents from customers, and explaining how they operate; and

(b)

in the event that the relevant funeral plan contract will not continue to be carried out by the firm or another firm, the relevant customer or covered individual will promptly receive a payment corresponding to the funeral plan customer balance.

2A firm should also explain the particular risks to the carrying out of funeral plan contracts in the event of its failure, including the possibility that funeral plan contracts may cease to be carried out before the covered individual’s death, and that customers may need to make arrangements with an alternative provider and potentially incur associated costs.