Liverpool Victoria Financial Services Limited · DRN-6114089

The complaint The Estate of Mr F have complained about the service received from Liverpool Victoria Financial Services Limited (LV). What happened Mrs F is representing the Estate of Mr F and so I will refer to her throughout this decision. Mr F had two level term life insurance policies with LV. I understand that he changed providers and so the policies lapsed. I have been provided with the terms and conditions of the policies which set out that a complaint could be referred directly to LV, and to this service free of charge. Very sadly Mr F was diagnosed with a terminal illness in August 2024 and sadly passed away in October. On 18 December 2024 Mrs F called LV, I have been provided with a copy of the call recording. Mrs F explained that she was calling to see if a claim could be made, she said that Mr F’s new insurer had not paid the claim that was made. The adviser asked questions about when Mr F had been diagnosed, they left Mrs F on hold to check information with other departments. The agent explained that a claim couldn’t be made. The call ended with Mrs F being very appreciative that the agent had checked things for her. In February 2025 a Financial Conduct Authority (FCA) regulated claims management company (Firm R) contacted LV to question their decision not to pay the claims. This resulted in a formal complaint being referred to LV on 18 February 2025. LV agreed to assess a terminal illness claim on 20 February 2025 and the complaint was closed. The claims were paid and a second complaint referred to LV. Firm R, on behalf of Mrs F, complained about the service she received during the initial call with LV, and due to letters, that were issued in Mr F’s name following the reinstatement of the policies which had caused Mrs F distress. On 15 August 2025 LV issued a final response letter, they apologised for issuing letters in the late Mr F’s name and for the delay that had been caused to the claims being paid. They offered to pay £1,187.68 interest calculated from Mrs F’s first contact with them to the decision to assess the claims – minus any relevant tax plus £100 compensation. Or alternatively to pay £1,000 compensation in total. Mrs F remained unhappy and referred the complaint to this service. Mrs F explained she felt that LV had failed in their duty to her which led to her having to use the services of a no win no fee firm to assist with the claims. She said she has suffered due to the level of service she received and would like LV to reimburse the fee she had paid to Firm R. LV provided a further final response letter on 22 September 2025. They said Mrs F was able to refer her complaint to them directly, or via this service and both avenues are free for Mrs F. So, they don’t think it fair that they be asked to cover Firm R’s fee. In addition, LV mentioned that Firm R reduce their fee by 10% if potential clients have not complained directly to the firm (LV in this case) or this service. LV offered an additional £1,000 compensation for the service they had provided.

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An investigator issued their assessment; they felt that the offer LV had made to resolve this complaint was fair and reasonable. About Firm R’s fee, the investigator said it wouldn’t be reasonable to ask LV to reimburse it. That was because a complaint referred to LV directly or to this service would have been free of charge for Mrs F. And Firm R’s reference to a discount suggests that consumers can make a complaint either directly or via this service. Mrs F disagreed with the assessment, she said in summary: • There was no motivation to use Firm R in relation to a reduction in their fee. She wasn’t aware of and didn’t benefit from a discounted fee. • There was no complaint to be made during the telephone call in December 2024 because Mrs F assumed LV were correct when advising her they wouldn’t pay the claims. She feels she should have been advised of her right to complain if she was unhappy with the outcome. She didn’t know she could complain. • LV are a large organisation she didn’t feel able to challenge their position. • Mrs F would not have used the services of Firm R. She would have pursued things herself. She didn’t know at the time she had any other choice. • Consumers who are not experienced in these circumstances or the complaint process can’t reasonably be expected to challenge large companies without being informed of their rights. This is why CMC firms exist. The investigator explained that consumers of large financial services firms make complaints regularly. That LV’s website sets out their consumer’s right to complain and the right to refer a complaint to this service with a link to our website. Where consumers don’t feel able to bring the complaint themselves, they can ask a friend or relative to assist them or alternatively appoint a CMC or solicitor which will incur charges or a fee. Mrs F asked for an ombudsman to review the complaint. She explained at the time of contacting LV she was bereft, felt unable to deal with complex insurance issues and emotionally unable to challenge the decision made. Had she been properly signposted she wouldn’t have instructed Firm R. This led to her losing a large proportion of the claims in fees. Mrs F asked for the compensation amount of £2,000 to be reconsidered in light of: • Increased impact on Mrs F as a recently bereaved and vulnerable consumer. • Prolonged distress and anxiety caused. • LV’s complaint handling failures. • That Mrs F was deprived of the opportunity to pursue her complaint independently and without financial penalty. The complaint was passed to an ombudsman for a decision What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Whilst I have considered everything that has been provided to this service, I don’t intend on commenting on each item. Instead, I will focus on what I have determined are the key aspects of the complaint. When considering what’s fair and reasonable in the circumstances, I need to take account of relevant law and regulations, Regulator’s rules, guidance and standards and codes of practice, and what I consider to have been good industry practice at the time.

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I appreciate this will come as a disappointment to Mrs F, but I’m not asking LV to increase their offer of compensation. I have read through all of Mrs F’s communications with this service and thank her for explaining in detail how she has been impacted by the sad passing of her husband and this complaint. I will go on to explain in detail why I’m not asking LV to do anymore. Opportunity to pursue a complaint independently – reimbursement of Firm R’s fee Mrs F has explained that she doesn’t feel she was adequately signposted to the free alternatives when referring a complaint about LV. And she says this led to her incurring a large fee which she would like reimbursed. I can only make a financial loss award where I find a firm have made an error. And where that error has directly led to a financial loss. The regulator – the Financial Conduct Authority (FCA) tells regulated firms how they should operate by providing rules and guidance to them. Both LV and Firm R are regulated by the FCA. In relation to LV’s complaint process, they are obligated to: • Have an internal complaint process details of which should be provided to their consumers at the point of sale. I note the terms and conditions document provided information about how to complain directly with LV and refer a complaint to this service. I appreciate Mrs F may not have had a copy of this in late 2024 when she contacted LV. • Details of the complaint process should also be published by LV. LV’s website has a lot of information about how to complain directly, and it includes information about escalation to this service. A reasonable search of their website would have brought this information to Mrs F’s attention. • They should send a copy of their complaint process when they receive a complaint. “Complaint” is defined within the FCA handbook which, amongst other things, sets out that a complaint is an expression of dissatisfaction either written or orally. I have therefore listened to the call Mrs F made to LV in December 2014 to establish if LV should have explained or provided their complaint process to her. Having done so I can’t agree that Mrs F expressed dissatisfaction with the information she was provided with by LV. Mrs F was grateful for the time the agent spent checking things, and the call ended with her thanking the adviser. So, I can’t agree that LV ought to have explained their complaint process to Mrs F during this call, or logged a complaint to be dealt with. I appreciate this will come as a disappointment, but LV didn’t act incorrectly by not explaining their complaint process to Mrs F in December 2024. So, in relation to this point they didn’t make an error, so I’m not upholding this part of the complaint. Mrs F has said she was unaware that she could complain directly to LV, or refer her complaint independently to this service free of charge. There have been some comments throughout this complaint about Firm R’s communications which included an incentive not to complain directly before engaging them. I don’t think these comments have been helpful for Mrs F – as any offer of a discount from Firm R makes no difference to the outcome of this complaint.

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In addition to the above, Firm R are also regulated by the FCA and they had distinct obligations to Mrs F. I can’t comment on whether Firm R acted correctly within this decision as I am reviewing the actions of LV only. And I haven’t been provided with any evidence to establish things either way – such as their signed terms and conditions. However, Firm R are obligated to explain to Mrs F that there are free alternatives available to her and clearly explain those options prior to their engagement. And they should have asked Mrs F to confirm she didn’t want to make a complaint herself for free. And so, even if I agreed that LV had made an error, and they should have told Mrs F that she could complain directly but didn’t, I still wouldn’t award compensation. That is because, when Mrs F approached Firm R they ought to have explained her options to her. And so, had Mrs F felt able to pursue her complaint directly she would have been provided with those options by Firm R and could have done so. And therefore, not incurred the fee. So, I would still not ask LV to reimburse the fee Mrs F has incurred by using a CMC. Compensation and interest LV have offered two options to Mrs F in relation to compensation for the service they have provided to her and the loss of interest on the claim monies. • £1,100 compensation and £1,187.68 interest subject to a 20% tax deduction. Which may possibly be able to be reclaimed by Mrs F. Or • £1,000 compensation and £1,000 compensation which includes consideration of the loss of use of the claim monies, but this amount won’t be subject to a 20% tax deduction. As set out above, I’ve not found that LV failed in their duty to Mrs F in relation to their complaint process. However, LV agree they should have started the claim process sooner and have offered compensation to her in relation to the delay this caused to the claims being paid and inconvenience they caused. I have considered everything Mrs F has explained about how she felt vulnerable and was already at a heightened state of stress due to her husband passing. I agree that LV’s actions will have exacerbated that stress, particularly by them sending letters addressed to Mrs F’s late husband. So, I agree that it was correct for LV to offer compensation. The amount offered is in line with what I would have suggested where an error has caused substantial distress, upset and worry, as Mrs F has described, if no offer had been made. And so, I’m not asking that they increase the offer. In addition, LV have offered to pay interest for the period of delay they caused which is a fair way to redress this part of Mrs F’s complaint. They have offered an alternative cash amount, Mrs F will need to let LV know which she would prefer prior to compensation being paid. Summary LV met their obligations to Mrs F in relation to providing information about alternative, free ways to make this complaint. And, even if they hadn’t, Mrs F engaged a regulated CMC who had obligations to explain the free alternatives to her before she chose to utilise them. I’m satisfied that Mrs F therefore had enough information – or should have done, for her to pursue this complaint without the use of a CMC had she chosen to. So, I’m not asking LV to reimburse the CMC fees which have been incurred.

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Mrs F has explained she was in a vulnerable position which was made worse by LV not accepting the claims in December 2024 and issuing letters in her late husband’s name. It’s right that compensation was offered, and the amount is in line with the substantial impact Mrs F has described. LV have offered to pay interest for the loss of use of the funds which is a fair way for them to resolve that part of this complaint. Putting things right LV have made two offers to Mrs F in relation to compensation, if she agrees with this decision she will need to let LV know which option she chooses before they redress her. I direct LV to pay Mrs F, on receipt of her choice of option: A. Pay Mrs F £2,000 compensation which has no interest element. Or B. Pay Mrs F £1,100 compensation and calculate and pay Mrs F 8% simple interest per annum on the total claim monies received for a period of 65 days. This is to reflect the delay caused to the payout of the claims between 18 December 2024 and 20 February 2025. My final decision I uphold the Estate of Mr F’s complaint and direct Liverpool Victoria Financial Services Limited to pay redress as set out above. Under the rules of the Financial Ombudsman Service, I’m required to ask the estate of Mr F to accept or reject my decision before 21 April 2026. Cassie Lauder Ombudsman

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