Howden Life & Health Limited · DRN-6248469

The complaint Mr D complains that Howden Life & Health Limited misold his private medical insurance policy. What happened Both parties are very familiar with the background of this complaint so I will only set out what happened in brief. Mr D had a private medical insurance policy. It was sold to him in August 2024 by Howden Life & Health Limited and underwritten by an insurer I’ll call “X”. Mr D went on to utilise his policy but exceeded its outpatient benefit limit and became liable for the overspend. Mr D initially raised concerns about going over those limits with X, but in July 2025 he complained that Howden had misold the policy to him too. Mr D said Howden hadn’t explained the outpatient cover limit during the sale, and the policy materials it had provided were unclear about cover for x-rays and ultrasounds. Howden disagreed. It ran through the sales calls and the materials provided and said Mr D had been given detailed information about the outpatient limitations. It also said whilst its advisors aimed to explain key aspects of a policy, they couldn’t cover every detail of it so strongly encouraged clients to thoroughly review the full policy documents. Unhappy with that, Mr D brought his complaint to this service and said he wanted the policy changed, to include the cover he thought he was going to get, or the amount he’d overspent on the outpatient benefit refunded. Our investigator said Howden had a responsibility to provide Mr D with enough information for him to decide if the policy was right for him. And, having considered everything they didn’t think the policy had been mis-sold. Mr D disagreed with that however, and said Howden had acknowledged the policy material was misleading during a post-complaint call. Our investigator confirmed they had listened to that call as part of their investigation and remined of the opinion that the policy hadn’t been mis-sold. So, as no agreement was reached the matter was passed to me to decide. I issued a provisional decision and explained I didn’t think Mr D’s policy had been mis-sold, but for different reasons to the investigator. That decision forms part of this final decision, and it read as follows: “I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Before I explain my provisional findings, I want to set out that I’ve summarised events in less detail than they’ve been presented but have considered everything that’s been said. I won’t however address all individual points made and will instead focus on those matters I

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consider central to the outcome of this complaint. Insurance policies can be sold on an advised or non-advised basis. And the relevant rules and industry guidance explains how a seller’s responsibility will differ between the two. In an advised sale, a seller needs to ensure that the policy it’s recommending is suitable for the consumer’s circumstances and needs at the time. In a non-advised sale, the seller needs to provide enough clear, fair, and not misleading information in order for the consumer themselves to decide that the policy is right for them. Howden sold Mr D’s policy on an advised basis. So, his complaint needed to be considered against those responsibilities. That difference is why I am issuing this provisional decision, and for the following reasons I too am currently of the opinion that this policy wasn’t mis- sold: • The initial sales call between Mr D and Howden took place on 17 August 2024. During it subjects such as how much Mr D had wanted to spend on a policy, the different levels of cover available, and the providers being offered through Howden took place. Mr D’s personal details and medical history were obtained. Moratorium underwriting was explained. And policy tailoring, such as whether Mr D had wanted additional cover options like cancer, mental health, and dental benefit for example, were discussed. Two quotes were then produced and having looked at them, they appear to have correlated with what Mr D said he wanted at the time. • Howden then gave Mr D some time to consider those quotes, and on 27 August 2024 it spoke with him again. Mr D confirmed which policy he wanted to proceed with. Howden ran through many of the chosen policy’s features again. And it also said: “We’re completing this application over the telephone. We’ve briefly outlined the policy information. I’m going to be forwarding you full details about us and your policy, and it is important that you read this documentation and understand exactly what is and is not covered. Can I just clarify, are you happy to proceed on this basis?” Mr D responded “yes”, and details about Howden and the policy were sent on as agreed. • The welcome letter Howden issued outlined the policy details and asked Mr D to read all the enclosed literature to ensure he understood the terms and conditions of the policy. It confirmed Mr D had a combined £500 benefit for consultations and diagnostic tests, set out that for full details of cover he should see the policy brochure, and asked Mr D to get in touch if he required any assistance or support. The policy brochure provided also set out how the £500 out-patient cover worked – with CT, MRI and PET scans being covered in full, and diagnostic tests such as blood tests, x-rays and ECGs being subject to the £500 limit. I don’t think the policy documentation provided by Howden was unclear. And whilst I appreciate ultrasounds weren’t listed as included in the above, I don’t think it automatically follows that means they should be assumed as included. • At the time of selling the policy, Mr D didn’t have a significant medical history. He’d

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told Howden he only had one pre-existing medical condition and was in good health generally. It is of course unfortunate that Mr D exceeded his outpatient benefit, but I don’t think that Howden could have reasonably foreseen that he’d do so. Based on what Mr D had indicated he wanted from a policy at the time, I believe that what Howden recommended and then sold was suitable. And I don’t think the policy documentation it provided was unclear. • I understand Mr D says that Howden acknowledged the material it provided was unclear during his post-complaint call. I didn’t note Howden saying the documentation it provided was unclear – and the call handler stated very clearly towards the end of the call that they didn’t feel that way. But, even if the call handler had said they felt the documentation was unclear, I’m not persuaded it would be fair of me to ignore everything that had already taken place as part of the sale in 2024, and all the steps Howden had taken to ensure the policy was suitable for Mr D’s circumstances and needs at the time. • For all the reasons give above, I currently think that Howden recommended a policy that was suitable for Mr D circumstances and needs at the time. And the policy material it provided was not unclear. I realise Mr D is likely to be disappointed, but currently I’m not persuaded that Howden mis- sold this policy. While I empathise with the position Mr D ultimately found himself in, I don’t think it would be fair of me to interfere with Howden’s current position.” Responses to the provisional decision Both sides responded to the provisional decision. Howden didn’t make any further submissions when it responded, but Mr D did. Mr S said he disagreed with the provisional decision and didn’t understand how the above conclusions had been reached when the policy documentation was unclear and that had been admitted by Howden in the post-complaint call. Mr D reiterated details of that specific call, said the service had sided with a company in the industry we were supposed to regulate, and provided an online article about the service too. So, I now need to reach a final 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. Having done so, I have reached the same outcome as my provisional decision. I appreciate Mr D still feels very strongly about the post-complaint call with Howden. I would like to reassure him that I listened to all the call recordings provided in full. But, as I set out above, it would not be fair of me to discard the entire sales journey that took place because of one post-complaint call. I also think it important for me to explain that this service is not a regulator. We consider individual complaints on their own merit. Whilst I thank Mr D for taking the time to provide the article and appreciate his own views of the Financial Ombudsman Service, I remain of the opinion that this policy was not mis-sold.

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I realise Mr D is likely to be further disappointed by these findings, but for all the reasons here and within my provisional decision I will not be interfering with Howden’s position. My final decision My final decision is that I do not uphold this complaint against Howden Life & Health Limited. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr D to accept or reject my decision before 22 April 2026. Jade Alexander Ombudsman

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