Annex A - Representations received during the consultation exercise
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Representations received during the consultation exercise
| Letters | Emails | Faxes | TOTAL | |
| MPs | 204 | 5 | 2 | 211 |
| Action Groups | 3 | 0 | 0 | 3 |
| Policyholders | 1,269 | 291 | 43 | 1,603 |
| Government bodies | 4 | 0 | 0 | 4 |
| Interested parties | 14 | 0 | 0 | 14 |
| TOTAL | 1,494 | 296 | 45 | 1,835 |
Notes:
1. Multiple responses from individuals have been consolidated and are reflected as a single representation.
2. One joint letter (from Dr Vince Cable MP and Norman Lamb MP) has been counted as two representations. Two members of the public who say they are not policyholders have been included in the policyholder numbers as they both said that their partner is a policyholder.
3. Where letters from individual policyholders have been forwarded by MPs (there were 148 such letters), these have been counted as if they were a direct individual policyholder representation.
4. The three action groups were the Equitable Members' Action Group (EMAG); the Equitable Life Trapped Annuitants (ELTA); and the Equitable Members' Help Group (EMHG). The four government bodies were the Treasury; the Financial Services Authority; the Government Actuary's Department and the Department for Trade and Industry. The 14 interested parties were the Public Administration Select Committee; the Treasury Select Committee; Equitable Life; Lord Penrose; the National Association of Pension Funds; six pension fund trustees; one Peer; the Consumers' Association; and a member of the public.
5. In addition to the above, there were eight referrals of new complaints about Equitable received during the consultation exercise and 44 very late submissions (i.e. received after the end of May 2004). I continue to receive representations.
Responses from Members of Parliament
A1. I received submissions from 211 Members of Parliament (from a total of 657 non-vacant seats at the relevant time, representing a response rate of 32.12%). 167 asked me to conduct a further investigation; the remainder made no personal submission on the matter.
A2. Of the total received:
- 56 were Labour MPs (from 408 - this reflects a 13.73% response rate)
- 134 were Conservative MPs (from 163 - this reflects a 82.21% response rate)
- 13 were from Liberal Democrat MPs (from 54 - this reflects a 24.07% response rate)
- 8 were from other parties (2 Plaid Cymru, 2 Independent Conservative, 2 Scottish National Party, 1 Ulster Unionist, and 1 Independent - from 34 - this reflects a 23.53% response rate).
A3. Of the 211 letters from MPs received:
105 were 'substantive representations' (i.e. put forward the MP's views on whether I should conduct a further investigation and on what basis) - this number is made up of 23 Labour, 67 Conservative, 9 Liberal Democrat and 6 'other' MPs.
- 62 were 'associative representations' (i.e. short letters, associating the MP with the views of another): of these, 60 associated the (Conservative or Independent Conservative) MP with the letter from Andrew Tyrie and 2 Liberal Democrats associated themselves with that from Vincent Cable and Norman Lamb.
- 44 were 'non-substantive representations' (i.e. a letter from the MP covering the submission of constituents' letters while making no personal representation) - 33 of these were Labour, 9 were Conservative and 2 were Liberal Democrat.
Responses from Policyholders
A4. I received 1,907 representations from 1,603 existing and former individual policyholders. Multiple or follow-up representations have been consolidated and the following figures reflect the number of people making representations not the number of separate submissions, many of which were duplicates while others were follow-ups.
A5. All but four individual responses urged me to conduct a further investigation.
A6. Of these 1,603 individuals:
- 358 were existing complainants whose complaints about Equitable Life had already been referred to me. This was from a total of 591 referred complaints on hand at the beginning of the consultation period, reflecting a response rate from this group of 60.58%.
- 33 were people who had contacted my Office direct about Equitable Life before but who had not had their complaint duly referred to me.
- 12 had had a previous complaint, not related to Equitable Life, dealt with by my Office but who contacted me about Equitable Life for the first time during the consultation exercise.
- 1,192 contacted my Office for the first time during this process.
A7. In addition, I received 8 new referrals from 5 MPs (bringing the total number of referred complaints to 599).
A8. Of the 1,603 individuals making submissions:
- 503 are existing with-profits annuitants.
- 179 have or had Guaranteed Annuity Rate (GAR) policies.
- 201 have or had non-GAR policies.
- 47 are or were members of a company pension scheme associated with Equitable Life.
- 80 have or had made Additional Voluntary Contributions to Equitable Life.
- 485 referred to themselves as 'policyholder' without being specific about the type of policy they have or had.
- insufficient information was provided by 108 individuals to classify them under any of the above groups, although we can infer that they are policyholders from other information provided.
A9. Of the 1,603 consolidated representations received from individual policyholders and former policyholders:
- 191 (11.92%) used the standard template letter produced by Equitable Life Trapped Annuitants.
- 67 (4.18%) used the standard template letter produced by Equitable Members' Help Group.
- 172 (10.73%) used the standard template letter for 'trapped annuitants' produced by EMAG.
- 108 (6.74%) used the standard template letter for 'late joiners' produced by EMAG.
- 110 (6.86%) used the standard template letter for '1990s investor' produced by EMAG.
- 538 (33.56%) made personal (substantive) submissions - of these, 207 were in part based on one of the action group template letters (respectively: 45, 20, 58, 31, 53).
- 417 (26.01%) made very short personal submissions (usually around a paragraph in length, adding their support to calls for an investigation).
A10. In total, therefore, 648 template letters, 538 personal, substantive submissions and 417 summary submissions were received. The respective proportions are 40.43%, 33.56% and 26.01%.
A11. Respondents came from all regions of the UK:
- 636 (39.68%) were from the South-East of England or from East Anglia
- 226 (14.10%) were from the North-East or North-West of England
- 187 (11.67%) were from the Midlands
- 141 (8.80%) were from the South-West of England
- 126 (7.86% were from Greater London
- 52 (3.24%) were from Scotland
- 45 (2.81%) were from Wales
- 9 (0.56%) were from Northern Ireland - 16 (0.99%) were from overseas
- 16 (0.99%) were from overseas
- 165 (10.29%) were from people about whom we did not have enough information (primarily those contacting us by email) to be sure of their location.
