Protection network compliance directors have been warned to change their stance on restricting intermediaries from selling two single life policies, with the Financial Conduct Authority (FCA) aware of the issues around economic abuse.
Insurers have also been told to “just do it” and bite the bullet of splitting dual life policies where there is evidence of economic abuse.
The call comes from Johnny Timpson, advisory group member at Surviving Economic Abuse (SEA) who was speaking at the Women in Protection Conference 2026.
Timpson (pictured) explained alongside network compliance directors, a significant issue also remained with back books of policies.
As a result he is seeking to arrange an FCA roundtable to look into the possibility of insurers just accepting the business risk and splitting the policy where there is clear evidence of economic abuse.
Timpson maintained the regulator was very much alive to this issue in terms of Consumer Duty outcomes, vulnerable customer support and its work in relation to the Pure Protection Market Study and the government’s Financial Inclusion Strategy.
Link long established
The link between joint life policies and economic abuse has been long established, Timpson told delegates.
Professor James Davey at the University of Bristol Law School, Ron Wheatcroft, Jennifer Gilchrist, Ruth Gilbert, Timpson himself and others started working on the issue back in 2017 as part of what was then the Chartered Insurance Institute’s Insuring Women Futures Programme.
Campaigners have also raised awareness of the issue of tackling economic and financial abuse together with coercive control as a cross cutting issue within the government’s HM Treasury led Financial Inclusion Strategy – a strategy that as a member of the UK Financial Inclusion Commission, Timpson added he is proud to have lobbied for.
Timpson further pointed to a policy paper from the Surviving Economic Abuse Charity, life insurance guidance from the Personal Finance Society, general insurance guidance from the Chartered Insurance Institute and Association of British Insurers (ABI) as a Financial Inclusion Strategy Action developing guidance for all other product areas.
CI Expert has also been promoting a Single is Best Initiative to life insurance sales with several benefits cited, including reducing economic abuse.
Insurer back books
However, Timpson added a significant issue remained with back books where a mechanism for splitting policies is lacking without a splitting policy clause nor agreement between the lives assured.
Timpson contended that an “implied term” legal argument on the basis that it is implied that both parties fully consented to the taking out of a life policy could be a way forward.
But he added this would need to be tested in the High Court, so a more pragmatic solution could be for insurers to ‘just do it,’ and accept the business risk where there is clear evidence of domestic economic financial abuse or coercive control with one party who is not going to agree with the cancelling or the splitting of the policy.
He further explained there was industry precedent for this ‘just do it’ approach as it is what the friendly society movement is doing with disabled children in enabling access to child trust funds so that they and their families do not have to incur court of protection legal costs.
FCA roundtable
In order to avoid competition conflicts, Timpson added his aim is to ask the FCA and/or Chartered Insurance Institute and Institute and Faculty of Actuaries to convene a roundtable on this issue.
But addressing the network compliance directors in the room specifically, Timpson said: “The FCA are really plugged into that and it speaks to all the work that the FCA is doing particularly on Consumer Duty, focusing on support and of course the pure protection market study.
“So the Treasury has said tackling economic financial abuse is the cross cutting issue for the financial services industry,” he added.
“We have guidance for wealth managers and all protection advisers from the PFS.
“We have guidance for all general insurance brokers from the Chartered Insurance Institute.
“We have Consumer Duty guidance as well as economic financial abuse for all products from the Surviving Economic Abuse charity.
“And there’s all the product guidance coming from the ABI.”
‘Time to change’
Though Timpson added this issue was not just one for compliance directors, government or the Treasury as it involved the whole industry.
“The regulator’s on it and Consumer Duty vulnerable customer guidance and the Pure Protection Market Study,” he continued.
“You’ve got professional body guidance.
“What more does it take for you to review and change your current policy in terms of your policy practice for the sale of protection policies?
“Now is the time to change. I would suggest doing it before someone does it to you.”
