HL Partnership Limited · DRN-6215243

The complaint Miss S complains about HL Partnership Limited (‘HL’). She says she was mis-sold a Decreasing Life Insurance and Critical Illness policy by an adviser at the business. What happened Miss S originally took out her policy in 2022. This was an advised sale. At the point of sale, Miss S recorded that she was a single parent with one dependent child, self-employed as a hairdresser, owning her own home (mortgaged) with a remaining balance of £72,000. As part of the advice Miss S received, she was advised to take out a Decreasing Life Insurance policy with Critical Illness cover through an underwriter (‘Company L’). Company L provides two different types of critical illness cover: “Critical Illness” and “Critical Illness Extra”. Miss S says she received no advice about Critical Illness Extra as a suitable option for her. Miss S explains that since taking out her life insurance policy she has been diagnosed with a spinal cord injury. Her condition causes severe compression of the spine and required surgical intervention. Unfortunately for Miss S, there was a delay in her diagnosis and treatment. This means she suffers from long-term effects of this condition, including paralysis, chronic incontinence, and chronic pain. She says the physical effects of her condition are visible, including the need for a wheelchair (or in the absence of one a crutch) along with extreme agonising pain. Emotionally, the impact is just a severe, and she has received treatment for her mental health (including therapy) and close personal relationships have also broken down. She explains how her illness makes it difficult to manage her salon and work like she used to. So she looked into whether her Critical Illness policy would be payable given her medical diagnosis and inability to work fully. However, Miss S explains when she called Company L, she was told she wasn’t fully covered and her illness would not result in a successful claim through the policy. Miss S says she then contacted the adviser she originally spoke to at HL, who set up her policy. And after they looked into the terms, the adviser called Miss S and explained that she does not have the cover she thought. The adviser explain that the standard critical illness cover was advised based on her budget at that time. Miss S complains that: - The policy was mis-sold - There has been an incorrect assessment of her needs

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- Communication regarding an appropriate policy was done via email exchanges, which were brief. - She made her requirements clear so needed cover in the event of death or critical illness, which she says her adviser failed to set up. Miss S says she suspects the facts of the policy were misrepresented to her. And because she wasn’t adequately informed of exclusions, the product was mis-sold. Miss S complained to HL. HL investigated the complaint and provided a response in August 2025. Within this response, HL says: - Miss S accepted the financial advisers’ recommendations when reviewing her protection arrangements. - Upon reviewing the file, the business recognises there would have at least been a need for comprehensive critical illness cover and total permanent disability cover to be discussed, but it cannot see this happened. - However, a copy of Miss S’s medical records from her GP has been obtained, and this showed two pre-existing health conditions which were not disclosed during the application process. The two conditions being back pain and asthma. - Had these medical conditions been disclosed then Company L (as underwriters) would have completed a full medical review. Following this, two things would have likely happened: o Comprehensive Critical Illness cover would have been heavily loaded with premiums and would likely have been unaffordable; and/or o Company L would have excluded back problems from the cover as a pre- existing condition. - It therefore does not believe there was a missed opportunity to provide comprehensive insurance which would have likely covered Miss S’s current condition. - It does recognise there was a delay in issuing the complaint response whilst Miss S’s medical notes were obtained from her GP. But this likely added to her distress. So, an offer of £150 compensation was made to recognise the impact this delay likely caused. Miss S was unhappy with this response to her complaint, so escalated the matter to us. An investigator from our service looked into the complaint and found that HL had acted fairly and reasonably in the advice given to Miss S. He said she was recommended a policy that balanced the right level of cover with Miss S’s affordability. And that this met Miss S’s core needs. Our investigator added that with the benefit of hindsight he can appreciate Miss S’ position. However, he needs to consider what happened at the time financial advice was being offered. Based on what is recorded at that time, the key features of the policy Miss S agreed to take out were correctly described at the point of sale. He concluded that the policy wasn’t mis-sold.

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Miss S disagreed with our investigator’s view. She explained how she wasn’t offered or properly informed about Critical Illness Extra, which would have changed the outcome of what happened in 2025 when she sought to make a claim. She says she wanted “meaningful” cover and wouldn’t have scrimped on payments to compromise her protection. She says messages exchanged at the time included her willingness to pay higher premiums. She feels deprived of the opportunity to make an informed decision. Miss S also discussed concerns about how the advice she received from HL failed to meet FCA principles about a financial adviser acting in the customer’s best interests. She also clarified the point about her pre-existing medical conditions, saying how in 2016, she had an MRI scan, but this reported normal imaging. A lumbar x-ray in 2022 was also “unremarkable”. It wasn’t until 2023 that there was anything indicating a problem with her back, and it wasn’t until 2024 that she received her diagnosis. Our investigator was not persuaded to change his view. As an outcome couldn’t be agreed, the case was passed to an Ombudsman for 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. I have summarised this complaint and what has happened linking back to the crux of what Miss S says went wrong. The purpose of my decision isn’t to address every single point raised by all of the parties involved. If there’s something I’ve not mentioned, it isn’t because I’ve ignored it - I haven’t. I’m satisfied that I don’t need to comment on every individual argument to be able to reach what I think is the right outcome. No discourtesy is intended by this; our rules allow me to do this, and it simply reflects the informal nature of our service. Instead, I will focus on what I find to be the key issues and evidence relevant to this complaint. Having reviewed all the information in this case and having considered the investigator’s view, my decision is that HL did act fairly and reasonably when it provided advice to Miss S in 2022. I will outline how I have reached my decision. I’ve read through the fact find and suitability letter (called a “Recommendation Report) for the financial advice given to Miss S in 2022. HL recorded Miss S’s objectives as follows: “…[Miss S] wanted to ensure that if anything were to happen during the term of the mortgage that it was repaid in full to leave a debt free property to your child or if you were to suffer a serious illness you did not want to have to worry about your mortgage. You wanted to ensure that payments remained the same throughout so I have recommended guaranteed premiums” I can see Miss S’s needs were clearly identified as financial security as a mother with a dependent child. And how, because of her financial situation with a net of c£900 per month available after all expenses were paid, that insurance premiums needed to be affordable for Miss S. This is also explains why the adviser emphasised the need for keeping premiums guaranteed. The Recommendation Report goes onto advise Miss S to take out three separate insurance policies that would meet her needs. These were: 1. Protection needs - this is the policy with Company L for the Decreasing Life Insurance and Critical Illness policy

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2. Income protection needs – this is a policy with a separate insurer (‘Company C’) taken out which is to cover Miss S if she was unable to work for more than four weeks at a time (she would receive an income to cover the cost of her mortgage premiums each month to make sure this financial commitment could be met) 3. Home insurance needs – this is a policy with another separate insurer (‘Company L’) which covered buildings and contents insurance for Miss S’s home address. I am of the view that this Recommendation Report sent to Miss S at that time was clear, fair, and not misleading. It took into account and clarified what Miss S was seeking to do. This was to provide protection and cover for her and her dependent child. The cover recommended included death benefits, critical illness cover and income protection (when unable to work for four weeks or more). All of which seems to be reasonable based on what were her circumstances at that time taking into account her income and expenditure and what she declared within her medical questionnaire (no serious or ongoing health concerns). This advice also took into account her role as a self-employed hairdresser. Income protection would cover Miss S for long-term sickness absence from work (an employee benefit she would not have access to because of her self-employment status). This tells me that HL really thought about Miss S’s needs and advised her accordingly. Miss S talks about how HL had a duty to act in her best interest and there was a missed opportunity to do so. However, I don’t agree. I have seen sufficient evidence which tells me that HL properly assessed Miss S’s financial and professional circumstances at that time and recommended products that were suitable to meet her objectives and budget. To be clear, the advice provided needed to be suitable. This is not the same as the most suitable advice possible. Rather, suitable to what was discussed at the time. And looking at the information that was available, I’m satisfied reasonable advice was given. I’ve read through the guide to Critical Illness Cover provided by Company L, and Miss S’s condition is clearly listed as the second option under the “Critical Illness Extra” section of this guide. I can therefore see how, for Miss S, this feels like a missed opportunity to secure full critical illnesses cover for her that would have likely helped in her making a claim. I also take on board Miss S’s comment that she would have paid higher premiums and communicated this to HL at the time insurance was being discussed. I do, however, need to take a balanced view, and also account for the fact that we are looking at this situation with the benefit of hindsight. Miss S wouldn’t have known, or expected at the time, that she’d be diagnosed with a condition. I agree with HL’s view shared that additional cover would have been more expensive. And as there was no indication from Miss S’s medical questionnaire that there were any concerns about her health, standard cover seems reasonable. I note that HL asked for a copy of Miss S’s medical records when she raised her complaint, which Miss S consented to. HL reviewed these records and explained that had Miss S sought more comprehensive cover Company L in 2022, then Company L would likely have completed a more detailed assessment and requested her medical records. So HL did so to assess whether there was a missed opportunity to explore this cover. And having done so, HL identified information within Miss S’s medical records that would have made more comprehensive cover difficult to secure at a reasonable rate, or at all. HL say there are entries for Miss S between 2015 and 2016 which discuss her back pain impacting her “at work and at home”. Miss S had referrals to the musculoskeletal clinic, a prescription for pain relief and a referral for physiotherapy at that time connected with her ongoing back pain.

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Taking this information into account, on balance, I’m persuaded by HL’s view that had more comprehensive cover been sought, more medical information would likely have been obtained, and these records would have impacted Miss S’s premiums/insurability without exclusions. This therefore makes Miss S’s view that there was a missed opportunity to secure enhanced cover, at an affordable price, difficult to agree with. I appreciate how, for Miss S, this will be a very disappointing outcome. She has explained how, not only does she have a debilitating illness to manage alongside a reduced income, but also her mental health has been severely impacted because of all the stress of what’s happened, including the knowledge that she is not as well protected as she thought she would have been through her insurance policies. I have not come to this decision lightly. My role is to consider, on balance, what is fair and reasonable in the circumstances. And based on the information I have read, I do find that Miss S received suitable advice in 2022. My final decision I do not uphold Miss S’s complaint. As such, I do not direct any remedy. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss S to accept or reject my decision before 24 April 2026. Emily Bowyer Ombudsman

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