Fairer Finance & Funeral Plans: James Dunn Responds 3

fairer finance

Fairer Finance, a consumer group whose aim is to get people fairer deals from financial services, recently published a report into funeral plans. Over 200,000 funeral plans are sold each year in this entirely unregulated market, so the report took a detailed look at the major players in the funeral plan world and how they do business.

 

The report was funded by Dignity PLC, a £1.2bn FTSE 250 listed company, who are the second largest provider of funeral services in the UK. Dignity are also one of the largest providers of funeral plans in the UK. Although they funded the report, James Daley of Fairer Finance was quick to reassure readers that “Fairer Finance was given full editorial control of the report, including the right to criticise the conduct of Dignity.

 

As one of few investigations into the plan market, this report received a lot of press attention and is likely to be referenced for years to come. One of our founders, James Dunn, read the report eagerly on its release and collected some thoughts.

 

Within this post there is a number of questions addressed to Fairer Finance. We have sent these over to James Daley of Fairer Finance and will update this post in the event that he responds.

 

UPDATE 17/07: James Daley has responded to our questions. We have included his responses inline.

 

Information about our own funeral plan can be found here.

 

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Firstly, I’d like to say that I welcome the Fairer Finance report into funeral plans. Beyond may be a relatively new arrival to the funeral plan industry, but in the seven months since we’ve been selling plans we’ve quickly learnt that the industry is in a bit of a mess.

 

Actually, let’s not beat around the bush – it doesn’t take a genius to see that the funeral plan market is a disaster waiting to happen. Widespread reports of pressure selling, opaque funds, comparison sites with no comparison, families left making up shortfalls, funeral directors refusing to take plans…this litany of malpractices adds up to a prime time TV expose in the making. This list of murky practices is longer even than the list of clauses found in many plan contracts.

 

So, against this backdrop, we thought it would be remiss of us not to put a few questions back to Fairer Finance (and their sponsors, Dignity) on their report.

 

Commissions, commissions, commissions. What is fair? What is reasonable? And where, oh where is Age UK’s tasty £9.4 million?

 

Commissions. You get someone else to sell your product because you don’t believe you can sell it yourself. In return, you’re happy to give them a kickback for selling the product you couldn’t sell. Commissions are odd, commissions are murky.

 

The report rightly identifies one of the key concerns with commissions, “it is often difficult for customers to tell where their money is ending up”.

 

Golden Leaves, Golden Charter and Safe Hands are all identified as companies paying commissions. The author mentions other cases and ends with the forthright conclusion that, “High-pressure sales and misrepresentation of products identified by this report are likely to be driven by the commission received by operatives for making a sale”.

 

It’s pretty odd then that the report totally fails to question Dignity over their relationship with Age UK and the commissions paid. This was big news last year with Age UK castigated for accepting millions of pounds to promote a particular funeral firm – which allegedly charges significantly more than some rivals.

 

It took us only a cursory search to find the figures that drew this outrage. Age UK sold 18,000 funeral plans for Dignity and got an eye-watering £9.4 million back.

 

It does not take advanced calculus to figure out this is £522 commission per plan sold. Great work for a charity helping the elderly if you can get it.

 

And so, my first question to James Daley of Fairer Finance is…Why did you not look at the commissions paid by Dignity to Age UK and why did these not feature in your report?

James Daley confirmed that he had asked providers about commissions and that they did not want to share them with him. Mr Daley states that he had not previously seen the Age UK article we referenced in the Independent. He has now raised this with Dignity and is awaiting a response. Mr Daley states that he agrees with our sentiment that commissions are probably too high and that he believes at the very least they should be disclosed. Mr Daley also points out that he believes there are bigger issues concerning size of margins in the funeral industry generally.

 

The one where the author can’t get in touch with Dignity

 

Everyone expects a funded report to be somewhat relaxed on holding the funder to account. That’s just par for the course. However, it shows startling chutzpah to let the funder off the hook in one paragraph and then lay into their largest rival in the next.

 

The author, no doubt devoted to his quest for transparency and fairness, asked the Co-op what their admin fee was. We think this is a fair question so sympathise with the author when he writes, “Co-op refused to tell us how much it takes as an admin fee, claiming that this was commercially sensitive.”

 

Pretty clear to us that the author doesn’t think too highly of this. Yet, did our eyes deceive us when we read about Dignity’s admin fee just two sentences earlier?

 

On Dignity: “Dignity pays all customer money into a trust, after which a payment is immediately made back to Dignity to cover the costs of selling and administering the plans. It’s not clear how much this is.

 

I mean, bloody hell. There are two options here. Either the author failed to ask Dignity what their admin fee was or he asked them and then refused to report it. You just can’t get away with that if you then have a go at a company for not being transparent in the next paragraph.

 

So, let’s ask Fairer Finance then…Did you request the admin fee from Dignity? If you did, what was their response?

Mr Daley confirmed that he requested the admin fee from Dignity and that they did not disclose it. Mr Daley explains that the Coop was uncooperative with him at first and that this led them on balance to be a bit harsher to Coop than Dignity. Mr Daley adds that since the publication of the report the Coop has been more supportive. Mr Daley also points out that the word “also” was removed from our text and that this had been meant to imply that both Coop and Dignity had refused. We removed this because we felt it superfluous in the context but we recognise that this wording could be intended to put Coop and Dignity in the same bracket (i.e. both were asked and both refused).

 

Another example of fitting the evidence to the narrative is when the author looks at cancellation fees. Two customer quotes are used in this section to show customers’ distaste of these fees. One for Safe Hands, whose fee is £495, and one for Open, whose fee is £345.

 

Dignity boasts the second highest cancellation fee at £395 yet somehow not a single customer contacted by Fairer Finance had a bad word to say about it?

 

Caught between a rock and a hard place. How Dignity has its competitors in a bind over cremation fees…

 

Dignity is one of only two providers who fully guarantee cremation costs. Guaranteed costs are an unreservedly good thing for customers. They remove any question that there will be a shortfall in plan value when the time comes.

 

So, are Dignity good because they guarantee cremation costs?

 

Well, kind of.

 

The question the report fails to ask is ‘Why do these plans end up with such massive shortfalls?’

 

Could it have anything even remotely to do with Dignity charging the highest cremation fees in the country?

 

As our 2017 Cremation & Burial Cost Index showed, Dignity have the dubious honour of operating the most expensive crematoria in the country, charging a huge £999 in some areas. Nine of their sites charge this lofty thousand-minus-one price. To further burnish their high costs, Dignity operate 16 of the top 20 most expensive crematoria in the country. Without wanting to labour the point too much, the average price at a Dignity crematoria is 18% higher than the national average.

 

Put simply, a Dignity crematorium is an expensive place to be cremated.

 

Dignity aren’t just the most expensive cremation company. They are also the largest. Dignity control 44 of the UK’s 282 crematoria and are the only single company who can claim to have national coverage. Many locations will have local monopolies, as there are understandably stringent planning restrictions for the building of new crematoria.

 

These two points combine to put Dignity in a enviable strategic position.

 

Dignity can safely charge high cremation fees, and increase them each year, knowing that they will still be able to ‘guarantee’ this particular disbursement to their funeral plan customers.

 

Their competition, however, has to take a gamble.

 

On the one hand, increasing cremation fees force Dignity’s competitors to raise their ‘cremation contribution’ to ensure customers do not face a shortfall.

 

Yet, on the other hand, every pound they increase the contribution by raises the total amount the customer pays and therefore makes them more expensive compared to Dignity.

 

Dignity’s competition are in a pretty weak position here.

 

They either have to keep the disbursement contribution low and risk customers’ facing a shortfall…or, they have to increase the disbursement contribution and lose the customer to Dignity!

 

A third question…how can plan companies both compete fairly and avoid disbursement shortfalls, when one of their competitors has a vested interest in high disbursement fees?

Mr Daley responded by saying that price of services in the crematoria sector is a separate debate and that the important thing for prepaid plan customers is that they understand the costs and what their plan will cover before they buy the plan.

 

Picking on the little guy

 

In the section titled ‘Regulatory Breaches,’ the author again makes a valid observation. He points out that Safe Hands only show customers a total price on their product pages and that this puts them in breach of their association rules to provide customers with an itemised price list.

 

Pretty reasonable in my mind, and here’s how the author puts it: “The NFFD requires members to provide “all customers with an itemised price list, and to display this price list in a prominent place at all times.” Safe Hands simply shows headline prices on its product pages…An ‘itemised’ price list would show all costs, including administration fees and commission payments. These should be clearly separated from the headline cost. This is not what Safe Hands is supplying.”

 

Unfortunately however, the author has once again found a good point but then not provided anywhere near the full picture. You see, the NFFD is the youngest and smallest of the funeral trade associations. It is only a few years old and has only a few hundred members.

 

The most important two are the NAFD and SAIF. The NAFD traces its roots back to 1898, SAIF to 1989. Both have thousands of members. Both have a seat at the table in talks with government. Together they cover at least 80% of the funeral trade. I cannot imagine the author simply did not find them.

 

Although NAFD and SAIF are clearly in a different league to NFFD, they do have one area where are all three united. Can you guess what that its?

 

That’s right! They all have a Code of Conduct for members to abide to!

 

And, lo and behold, both have rules that tell their members to give customers an itemised price list. You can see their rules here and here.

Why, therefore does the author not make exactly the same point about Dignity (NAFD member), Co-op (NAFD member) and Golden Charter (whose stakeholders are SAIFCharter members), none of whom provide customers with itemised quotes on their product pages either?

 

It astonishes me that the author has gone out of his way to make a somewhat labyrinthine observation about one particular provider, but then failed to follow it through with anything approaching proper rigour and fairness when it comes to applying the same measure to the financial backer of his report.

 

And so, my final question is…Based on the same measure you used for Safe Hands, do you also agree Dignity, Co-op and Golden Charter are in breach of their trade association’s terms?

Mr Daley explained that the objective here had been to compare each business against their regulatory body and to identify rules breaches. In this case, it meant most providers were counted as falling under their plan regulator (the FPA) as opposed to their trade body association. Given that Safe Hands are not a member of the FPA, Mr Daley measured them against the code of their association body, the NFFD.

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3 Comments

  1. Golden Charter is not owned by SAIF. It’s stakeholders are SAIFCHARTER members.

    A small but significant point!!

  2. I’m afraid that the fashion of death is but a mere reflection of the fashion of life – with nowadays political correctness and moral indignation disguising themselves as moral fibre. The latter died a long time ago. A few of us may work towards its resurrection in the hope that honesty and service will be highly regarded and properly rewarded once more. However, at the moment, when articles like the one commissioned appear, it feels like pushing water uphill. Well done on a well written critique.

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Government Probate Fee Hikes to Hit Bereaved Families Hard 0

Family holds up piggy bank spilling out coins

In a controversial move, the government will be changing their official probate fees from £215 to as much as £6,000 for some bereaved families.

At the moment, families who need a grant of representation to settle the estate of someone who has died pay £215 in government probate fees, or £155 if they have professional help. Estates worth less than £5,000 are exempt.

Under the new fee structure, families settling an estate worth more than £50,000 will pay between £250 and £6,000, depending on the size of the estate.

Opponents of the new probate fees have called them a “stealth tax” that will hit vulnerable bereaved families hard.

However, the government has said that due to the higher threshold for fee payment, an extra 25,000 families each year won’t pay anything at all. 80% of those who will need to pay will face fees of £750 or less, with a maximum of 0.5% taken from any estate.

“Fair and more progressive”

In a written announcement, Parliamentary Under-Secretary for the Ministry of Justice Lucy Frazer MP said: “This new banded fee model represents a fair and more progressive way to pay for probate services compared to the current flat fee and reflects our commitment to protecting access to justice by ensuring we have a properly funded and resourced courts system.”

She also claimed that there were “several options” for families to fund the new higher fees and those who struggle to pay may be able to apply to the Lord Chancellor to remit the cost under exceptional circumstances.

“£10 million” in charitable income lost

As well as families, the change in probate fees could also have a significant impact on charities, which often rely heavily on the ‘legacy’ money that people leave to them in wills. The Institute of Legacy Management estimates that the higher charges could cost charities as much as £10 million a year in lost income.

Matthew Lagden, chief executive of the ILM, said that “The government’s own impact assessment acknowledges that the current fees cover the average costs of making a grant of probate, so we are clear that this is a stealth tax, which will be borne in part by charities,”

“We are also very concerned that the government’s impact assessment dismisses the costs to the charity sector as ‘not expected to be substantial’, when the £10m lost to this tax would fund vital services across England and Wales.”

What are probate fees for?

When someone dies, the executor of their will (or if there’s no will, their next of kin) needs to sort out their legal and financial affairs. Their money, property, assets and belongings all need to be passed on to the right people.

To access things like bank accounts, change property deeds, or transfer shares belonging to the person who has died, a grant of representation may be needed. This is an official document that states that a person has the legal right to settle the estate.

To set the grant up, the HM Courts and Tribunals Service charges a probate fee – so called because the kind of grant of representation you get is called a grant of probate if there’s a will. It’s called a letter of administration if not.

On average, 51% of estates in England and Wales can only be settled with a grant of representation.

How are the fees changing?

The current probate fee is a flat rate of £215 charged to DIY applicants, or £155 for those using professional help. It’s the same for estates of all sizes.

The new probate fees will be based on how much the estate is worth in total:

  • <£50,000: no fee
  • £50,000 – £300,000: £250
  • £300,000 – £500,000: £750
  • £500,000 – £1 million: £2,500
  • £1 million – £1.6 million: £4,000
  • £1.6 million – £2 million: £5,000
  • £2 million or more: £6,000

When will the higher probate fees come in?

The new fee structure will apply from April 2019 on.

What Do Customers Want From Funerals? 0

What do bereaved families want from funerals? Beyond CEO and Founder Ian Strang shares his take on why price transparency is just the beginning …

In a few weeks’ time, the CMA will publish a report concerning its enquiry into the funeral industry. The focus of this enquiry – and indeed, the focus of much of the media coverage around the industry over the last few years – has been cost. Are funeral costs going up or down? Are prices transparent? What can we do to help consumers with the cost of funerals? And so on*.

*The answers, by the way, are: flat for independents, up for chains; transparent for around 20% of the industry; and encourage people to use comparison websites.

These are worthy questions, and (disregarding my own self-interest here) it would be difficult for anyone to dispute the fact that Beyond has made huge strides in addressing the issue of price hikes and transparency over the last few years.

Because of our efforts, Dignity have been reduced to calling in the management consultants, and Co-op have (laughably) begun claiming to have started a price war (without actually publishing any pricing, but that’s a blog post for another time). The move towards fair transparent pricing throughout the industry is gradual, but likely now inevitable.

“Is it enough to simply make traditional funerals more affordable? I’d argue that it isn’t.”

But is it enough to simply make traditional funerals more affordable? Is that all that we can do to make bereaved families feel that we, as an industry, are meeting their needs? I’d argue that it isn’t.

When we talk about cost, and the public’s dissatisfaction with the cost of funerals, what we should really be talking about is value. Sure, people aren’t happy paying £5,000 for a traditional funeral with hearse and limousines – but in many cases, they wouldn’t be happy paying £500 for it either. It’s just not the service they’re looking for.

As an industry, we aren’t offering families a lot of choice. Yes, there are options out there if you dig around – you can find suppliers for anything from rockets that shoot your ashes into the air, to flammable Viking longboats. But these suppliers don’t (yet?) have the budget to advertise nationally, and many funeral directors don’t exactly push them.

“When you’re bereaved, feeling under pressure to organise a send-off – any send-off – and you know nothing about the industry, you’re not in any state to research different options. But families do want more choice.”

A lot of us in the business, intentionally or not, steer families towards a pretty standard format funeral. And when you’re bereaved, feeling under pressure to organise a send-off – any send-off – and you know nothing about the industry, you’re not in any state to research different options.

But families do want more choice, and we’re beginning to see some pushback.

Direct cremation is growing in popularity, for one. Often in a Sunday supplement or similar you’ll see articles about it: “Bury me in the garden”, “Stick me in a cardboard box”, etc. Many take a deliberately reactionary stance – rebelling against a status quo that dictates that a traditional funeral is the only “proper” option by shunning a funeral altogether.

That’s not surprising. It’s a lot like the dissatisfaction that many people feel with politics right now – “I don’t like any of the parties, so I won’t vote at all”. Direct cremation is also the least expensive of all the current options. But this recent increase in interest in direct cremation doesn’t mean that this is how the market will go or that it’s what people really want. Direct cremation is just the one of the few alternatives to a traditional funeral that’s easily available.

“No-one knows what bereaved families really want, because we haven’t been asking them. At least, not properly.”

So, what do bereaved families actually want, if not a traditional funeral?

Now, there’s no shortage of vocal factions promoting their own understanding of what families want, which generally correlates perfectly with something they are selling, whether that be service or a product.

But I’d argue that no-one knows what consumers want, because we, as an industry, haven’t been asking them. At least not properly, in a rigorous way.

To find out what the bereaved want, you need to ask them at the point of bereavement. You also need to offer them a wide variety of options, options which may not even exist yet. You also need to ask them in the exact same way each time, without the biases of different funeral directors, contexts or sales materials affecting their decision. And you need to ask a lot of people – at least 1,000 for any kind of statistical significance.

“It’s only now, at Beyond, that there are enough bereaved people going online and choosing funeral arrangements to create a data source set that’s robust enough to analyse. And analyse we do.”

It’s only now, at Beyond, that there are enough bereaved people going online and choosing funeral arrangements to create a data set that’s robust enough to analyse. And analyse we do. We constantly run tests across our website, much like any online business, to try and understand what users want.

Sometimes we invent a service and put it up online for a few weeks to see how much interest it gets. We might take it down again because no-one has clicked on it, but we still count that as a success, because the result is that we understand the consumer – bereaved people who need our help – better.

However, if people really like that service, we may look to develop it. This could be in tandem with our funeral director partners, or we might build an in-house offering, such as with estate administration. In that instance, our partners can then benefit by offering it to families themselves, increasing their service breadth.

“Over the next few years, the funeral industry is going to change more rapidly than anyone can imagine.”

Some of our partner funeral directors would rather we didn’t test. They see every new potential development on our website as a challenge to their business and post furiously about it on social media. This is short-sighted.

Over the next few years, the funeral industry is going to change more rapidly than anyone can imagine. It’s becoming ever-more-obvious that families are seeking different services, different ways to interact with funeral directors.

If individual funeral directors are not prepared to keep up with the pace of change, to invest in technology or partner with technology providers, to work in new ways, then they will stagnate. Because the chains certainly won’t sit still.

Dignity, despite previously being guilty of falling asleep at the golf buggy wheel, are now investing £50m in overhauling their business, introducing tablets, technology and home visits. The Co-op machine will likely respond in kind. And Dignity have the crematoria as an asset. You can see the benefit of that with their new “full-attended cremation service”, booked over the phone.

Will it be popular? I don’t know, but I’m impressed that they are testing new products for their customers. We’re interested to learn as well, so we’ve popped a similar product up on our website to find out whether this is the future or not.

“Funeral directors who embrace the testing, learning and development of new products to serve changing needs will flourish.”

For the first time in decades, we are starting to discover what consumers – bereaved families – really want. We need to be open to this journey of discovery and adaptable to the changes it will bring.

Those funeral directors that entrench solely around their traditional offerings and reliance on walk-ins for customer acquisition will slowly but surely die out. Those that embrace the testing, learning and development of new products to serve the changing needs of the bereaved will flourish.

Change is coming. Let’s embrace it, learn together and better serve the families who need our help.