Following work by both the FCA and the CMA, and the ‘loyalty penalty’ super-complaint, the CMA has published the terms of reference of its recently convened Loyalty Penalty Working Group (LPWG). The LPWG includes representatives from BEIS, FCA, HMT and Ofcom.
These terms of reference include:
- bolder enforcement and tackling harmful business practice;
- ‘nudge remedies’ best practice sharing; and
- consideration of targeted pricing intervention.
The LPWG will meet until at least June 2019, when their operations will be reviewed.