Norwich Union responds to CP170 - disclosure to consumers

Article date: 2 May 2003

Norwich Union is fully supportive of any proposals that help toenable consumers to understand the products they are buying. Thishas been clearly demonstrated through the leadership approach wehave taken through the Raising Standards scheme.

However, there are four key issues where we have seriousconcerns about whether the objectives of CP170 will berealised.

1. Costs of implementation РWe believe that theestimated costs in the consultation paper have been significantlyunderstated. We estimate that to implement the proposals NorwichUnion would need to incur multi-million pound costs. We thereforeexpect the total cost to the industry could be well in excess of£200 million, more than double the cost suggested.

2. Benefits – We do not believe that the marginalbenefits will justify the massive cost of implementing theseproposals. Huge steps have already been taken through RaisingStandards and the proposals could be achieved through incrementalimprovements to the current regime rather than wholesale change atdisproportionate costs.

3. Raising Standards – As a Raising Standardsaccredited provider, Norwich Union has been in the forefront ofimproving product disclosure information in both key featuresdocuments and illustrations to benefit consumers. The FSA’sown research for CP170, detailed in the consultation paper, statesthat the "completely remodelled version...was not significantlybetter understood than the Raising Standards version". Again thiswould suggest that for accredited brands the benefit of adoptingthese proposals would only be marginal, at huge extra cost.

4. Sandler review – We are currently in the middleof the consultation process on new simplified products, which bytheir very nature will demand new, clear pre and point of salematerial under Norwich Union’s proposed regime for theregulation of advice for these products. It would seem sensible towait until this consultation process is completed andunderstood.

Sally Shire, director of marketing strategy and communicationsat Norwich Union, said: "A vast amount of work has already beendone to lay strong foundations in terms of disclosure to consumers,in the form of Raising Standards. More discussion is needed todetermine the most beneficial route to build upon this rather thanre-inventing the wheel and incurring considerable costs in returnfor only marginal benefits for the consumer.

"We look forward to working with the FSA and the RaisingStandards Industry Standards Group to deliver an effective andaffordable regulatory regime, which meets our sharedobjectives."


Press office contacts:

James Evans - 08703 66 68 78 / 07790 487105
Ian Beggs - 08703 66 68 71 / 07790 487 533
Louise Goffee - 08703 66 68 70 / 07810 057362

Notes to editors

  • Norwich Union is the UK’s largest insurer. It is aleading provider of life, pensions and investment products and oneof the leading IFA providers. IFAs provide around 75% of thecompany’s long- term savings business.
  • Norwich Union has strategic alliances with building societiesand other leading UK brand names including Tesco Personal Financeand The Royal Bank of Scotland Group.
  • Norwich Union’s news releases are available on the Avivaplc website at
  • A selection of images are available from the Norwich UnionNewscast site at

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