Golden Leaves Managing Director, Barry Floyd, meets and responds to HM Treasury and the FCA

Golden Leaves invited to top-level talks with HM Treasury and FCA

Following the government’s announcement on the 1st of June of its consultation into the Funeral planning industry, we drafted and submitted our response paper to HM Treasury on the 30th of July


Golden Leaves was subsequently invited to a meeting with HM Treasury and the FCA on 2nd August to discuss it’s nationwide reseller business model, as well as the potential impact that increased FCA regulartion might have on the sector and specifically on the operation of the small to medium sized pre-need businesses currently operating in the marketplace.


The meeting was held at FCA headquarters in London, where a delegation from Golden Leaves consisting of Barry Floyd (Golden Leaves – Managing Director) Stephen Rowland (Golden Leaves -Chairman) and Arnold Pindar (Chairman of the UK National Consumer Federation and a Golden Leaves Trustee), met with David Reeves (HM Treasury Policy Advisor – one of the team leading the market study) and both Roy Bartholomew (Policy Advisor – Strategy and Competition Division) and Jason Pope (Strategy and Competition Division) from the FCA (The Financial Conduct Authority).

It is significant that a “smaller”, reputable and well respected FPA registered brand like ourselves, has been afforded the opportunity to debate market and regulatory issues directly with policy makers from the Treasury and the FCA. Important as this meeting was for the governments information gathering process, It was equally important for us to engage with the relevant officials, to ensure that policy makers fully appreciated that the funeral plan product is sold through an array of distribution channels in the current marketplace and by funeral and non funeral businesses of varying shapes and sizes, all operating very different business models.

It is particularly important to recognise that these different approaches, feed the differing demands and buying behaviours of the varying age groups purchasing the product in today’s society.

It was therefore essential to have policy makers recognise that (providing the correct sales process and prudential controls are in place) the client experiences no detriment whatsoever across any of the product distribution approaches currently operating side by side in the marketplace today.”  Barry Floyd – Golden Leaves MD

In such a diversified and competitive marketplace, it is also important to ensure that any new regulation is not only appropriate and targeted in order to protect the consumer but is proportionate and does not deliberately or inadvertently distort the market, diminish competition, or increase costs whilst reducing consumer choice (whether that be reducing their choice of product or indeed from whom, how or indeed where they decide to purchase that product).

Consumer protection is paramount of course but also whilst preserving the shape and integrity of the market. Not doing so would have far reaching and deeply negative implications on consumers, choice, costs and competition. This would fly in the face of Government’s stance on market competition and it’s wider policy approach, which was outlined in its Department of Business and Strategy’s green paper “Modernising Consumer Markets” that was published in April of this year.

“Consumer protection is at the very heart of everything we do here at Golden Leaves. Our approach is clearly evidenced, not only by the eloquent and robust compliance and onboarding programmes we operate to protect the consumer but also by the quality and reputation of our contingent of consumer protection focused GL Trustees. These include Arnold Pindar who is the Chairman of the National Consumer Federation and Jim Humble OBE –  a Vice President of the Chartered Trading Standards Institute.

We believe that high quality standards lead to innovation, improved consumer outcomes and underpin the very framework of positive market competition – which is clearly to the benefit of the consumer. ” Barry Floyd – Golden Leaves

Golden Leaves are supportive of the introduction of any increased regulation that is sensible, proportionate and above all appropriate not only to the product but also to the size of this particular niche marketplace.

In this regard, it was extremely encouraging that the Treasury and the Financial Conduct Authority appear to be taking seriously the views of all business profiles and not just the opinions of the large integrated funeral groups or supermarket funeral companies.

We have formally tabled our opinion that the FPA should be afforded statutory powers to ensure an appropriate level of regulation and oversight is compulsory for all funeral plans.