Kerry Underwood


with 49 comments

Below is the text of a letter sent by MORE TH>N, a trading name of Royal & Sun Alliance Insurance plc, to a solicitor’s client questioning whether the client had actually instructed those solicitors at all. That appears to be an actionable libel, but let that pass.

The letter then assumes that the client has indeed instructed the solicitors. It asks the client to confirm that fact and writes to this client of a firm of solicitors on the other side:-

 “When responding we would also ask that you confirm how you came to instruct the firm in question?” [sic]

 “Did someone else refer you to them?

Did they contact you direct?

Did you contact them direct?”

Towards the end the letter says:-

“Deliberately fabricating losses, or exaggerating the value of your losses, is an offence under the Fraud Act 2006.”

Imagine a solicitor writing that to a lay client on the other side who has already instructed solicitors. That would be getting into striking off territory. It is potentially contempt of court to seek to dissuade another solicitor’s client direct from pursuing a claim by what could be construed as a threat, where those solicitors have initiated a claim through the court process, which lodging a CNF clearly is.

It gets worse.

The client telephoned MORE TH>N and was offered £1,500.00 direct and told that her solicitor, Infinity Law Ltd T/A DGM Solicitors as in the letter, would charge her more and she would come out with hardly anything.

They also told her that she had 14 days to cancel and so her solicitors could not charge her anything.

Thus a client protection measure – the right to cancel – becomes a way of the other side, seeking to prevent the client having legal representation. That is obviously very harmful to the client and causes far more damage than not having the right to cancel in the first place. The other side here is a massive insurance company.
The writer of this letter, without irony, is described as a “Customer Services Director”.

Here is a link to the actual Letter, the text of which is set out below. 


Claims Department

PO Box 21561



T   0330 1023630

F   01403 325889


07 August 2015

Claim Number:

Our Insured:

Date of Accident:

Dear Mr

We have received a personal injury claims notification form from Infinity Law Ltd T/A DGM Solicitors, advising that that you have asked them to make a claim for injury on your behalf following a road traffic accident on the above date.

In the interests of preventing fraud, which has been on the increase, we hope you will not mind us writing directly to you in order to confirm that you are aware that Infinity Law Ltd T/A DGM Solicitors have made a claim on your behalf alleging you have suffered whiplash as a result of the above accident.

What to do Next

This depends on whether or not you have asked Infinity Law Ltd T/A DGM Solicitors to make a claim for these injuries on your behalf.

If you have asked the solicitors to make a claim on your behalf:

If you did ask these Solicitors to make a personal injury claim on your behalf, then we would be grateful if you could please confirm this to us. When responding we would also ask that you confirm how you came to instruct the firm in question? Did someone refer you to them? Did they contact you direct? Did you contact them direct?

After we hear from you, we will; not contact you again directly, and will deal exclusively with your solicitors.

Please contact us using any of the following methods quoting reference:

Email at:

Telephone on number 01422325255

Post Po Box 256 Wymond, NR18 9DQ

If you have not asked the solicitors to make a personal injury claim on your behalf:

If you have not asked Infinity Law Ltd T/A DGM Solicitors to make a claim for injury against our policyholder please contact us without delay by calling this dedicated number 01422325536 or by e-mailing us at We will take immediate steps to protect the position of your personal data and will also look into this matter further on your behalf.

If you do not want to pursue a personal injury claim, but have been told by an agency or other party that you will be charged a fee, please telephone us on 01422325536 and we will be happy to offer you further assistance.

It would be helpful if when writing you provide a telephone number in order that we can contact you to discuss this matter further.

Please be assured that any communication will be dealt with in confidence.

General Information for all Claimants:

Like most people we are sure that you will agree that exaggerating or making up claims against insurers is wrong, it cause motor insurance premiums to increase, and puts genuine victims of accidents in a bad light. We thank you for your assistance in helping us and the insurance industry as whole combat fraudulent claims.

As part of the claims process, we are obliged by law to register your personal details with the Department for Work and Pensions (DWP) Compensation Recovery Unit. The DWP works with insurers to recover benefits arising out of insurance claims.

We also pass claims information to the Claims and Underwriting Exchange (CUE), MIAFTR and other databases in order to assist with the prevention and detection of fraud. We may also search these and other databases, as well as share claims data with other insurers and organisations for the same purpose.

Deliberately fabricating losses, or exaggerating the value of your losses, is an offence under the Fraud Act 2006.


Thank you for your attention and assistance.

Yours sincerely


Customer Service Director

See also my related blogs as listed below:-








Written by kerryunderwood

October 21, 2015 at 9:05 am

Posted in Uncategorized

49 Responses

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  1. Yep

    Fairly standard

    See it all the time

    Martin Hulston

    Address: Clinch Solicitors Limited, Barnett House, 53 Fountain Street, Manchester, M2 2AN

    Tel 0161 441 0390 Fax 0161 441 0391

    Clinch Solicitors Limited, a company registered in England and Wales. The company registration number is 08558176 and registered office and address for service is Corn Exchange, Exchange Square, Manchester, M4 3TR. The list of directors is open to inspection at the office. Clinch Solicitors Limited is authorised and regulated by the Solicitors Regulation Authority SRA number 598975 (Clinch Solicitors Limited). Disclaimer – Clinch Solicitors Limited are Regulated by the Solicitors Regulation Authority. Access our Professional Rules at

    does not accept service of documents by fax or e-mail unless prior confirmation has been given in writing. If this disclaimer is sent to you at the foot of a message indicating that the recipient of your email is away from the office, any such confirmation is overridden. The recipient will not see your message until at least the time indicated. This e-mail is confidential and may contain legally privileged information. If you have received it in error, you are on notice of its status. If you are not the intended recipient of this message please notify us immediately by reply e-mail and then delete this email message from your system. Please do not copy this email or use it for any purpose or disclose its contents to any other person; to do so could be a breach of confidence. It is our policy to do our utmost to prevent transmission of viruses. However, this firm accepts no liability for any virus transmitted by this email or any attachments to it. Should you need further information or assistance please contact our systems administrator at

    Martin Hulston

    October 21, 2015 at 9:10 am

  2. Reminds me of Gavin Edmondson Solicitors v Haven Insurance, last time I heard this was due to be heard by the CoA in Mid November.

    Phantom2448 (@Phantom2448)

    October 21, 2015 at 9:17 am

  3. As a relative layman who is in PR/Marketing for a PI law firm with just some legal know-how, even I’m shocked at how unprofessional that approach is. Without even considering the grammatical and spelling errors in the letter.

    Defendant’s insurers writing direct to a claimant? No. Write to the law firm. They’re there as a buffer so that the claimant doesn’t have to deal with you direct!

    Question whether the lawyers have even taken instruction from the client? How would the case even progress without written consent and all the relevant info?

    Imply that the claimant might be exaggerating or making a false claim? How dare you!

    The entire misguided thing looks like it’s been written by an intern. Thanks for sharing, Kerry.

    • Justin

      As you will see from other blogs in this series this type of behaviour by insurance companies is common, so I do not believe that this is a one off by an intern.



      October 21, 2015 at 10:10 am

    • But what is the answer? There appears to be nothing regulating the conduct of an insurer vis a vis contacting a third party direct. There are the so-called codes of conduct but they have no teeth. there appears nothing in the protocol that would allow it to drop out of the protocol/off the portal for such conduct. I doubt if any additional costs can be claimed etc.


      October 21, 2015 at 10:27 am

      • It needs to be made a criminal offence carrying 2 years prison as per current similar behaviour outlawed and subject to 2 years prison in the Compensation Act.



        October 21, 2015 at 10:39 am

  4. I’m saddened, angry, disgusted and all kinds of emotionally drained by this. It seems every day a little bit of our professional standing is eroded away. By sending letters like this the insurers are achieving far more than using the backdoor to undersettle claims; they are also putting the seed into claimants’ minds that we crafty, low-life, underhand solicitors use whatever nefarious tricks we can get away with to get the poor, badly done to insurers to part with their money. It sickens me. Surely as a profession, collectively, we can do something about this? Sadly, I’m so worn out by the unremitting changes and bad press that we get that I just can’t think how…

    Deb Murphy

    October 21, 2015 at 10:21 am

    • Deb

      I agree with every word. Need to make this a political issue and constantly draw it to the attention of judges, press, MPs etc. The reality is that big business can get away with anything in the UK – that is why many well known huge corporations pay no tax.

      Keep at it! We will get this sort of thing made a criminal offence.



      October 21, 2015 at 10:35 am

  5. Kerry – do you know if anything is being done to challenge MoreThanIncompetent Insurance about this? I agree, this sort of behaviour is common, and we have to stand up to it as claimant solicitors

    Richard Powell

    October 21, 2015 at 10:26 am

    • Richard

      It requires all of us to keep at it all of the time. Without making a political point the fact is that this government won an overall majority on a pro- insurance company anti lawyer ticket. I appreciate that that was probably not the main thing on voters’ minds, but we need to educate everyone about this.



      October 21, 2015 at 10:38 am

      • How do we do this?

        Caroline McCarron

        October 21, 2015 at 10:44 am

      • Do what? As you will see masses of comments on this so not sure which one you are referring to?😄


        October 21, 2015 at 11:09 am

  6. Madness.

    Kerry, sorry for the off topic remark but can I send a message asking your opinion on something? If yes, how? If not, that’s absolutely understandable.


    October 21, 2015 at 10:43 am

  7. Dear Kerry

    We are getting letters such as this from LV and RSA.

    We have a client who received quite an irate telephone call when he refused, on my advice,to allow Countrywide to interview him. He is claiming from LV, his own insurers, as his wife, a name driver, caused the accident.

    They are now saying he is in breach of his policy by ‘failing to co-operate’ and the matter has been referred to their underwriters for ‘a decision.’

    I had the writer of said letter on the telephone and he was vile, he seemed to be taking the matter quite personally and was saying ‘tell me why you are tell OUR customer not to co-operate’ when as I pointed out he had co-operated,completed and returned their questionnaire and done everything asked of him and was willing to answer all and any questions – but he did not want Countryside calling to his home and wanted matters to go through his Solicitor. I have had experience of insurance company’s agents and I do feel their agenda is to get the result the insurance company are looking for. As the client is represented by us, it was inappropriate.

    Yours sincerely

    *From:* Kerry Underwood [] *Sent:* 21 October 2015 09:06 *To:* *Subject:* [New post] EVER SEEN WORSE TH>N MORE TH>N? – INSURERS AT IT AGAIN (6)

    kerryunderwood posted: “Below is the text of a letter sent by MORE TH>N, a trading name of Royal & Sun Alliance Insurance plc, to a solicitor’s client questioning whether the client had actually instructed those solicitors at all. That appears to be an actionable libel, b”


    October 21, 2015 at 10:44 am

    • Many thanks. I am getting loads of comments and emails concerning the conduct of insurance companies.


      October 21, 2015 at 11:01 am

  8. Hi Kerry

    If RSA have a law firm, is there not a conduct issue there? if I own another business as a solicitor I am still responsible for that other business’ actions – even if it is totally separate? Surely their ABS can be pulled up about this albeit it was sent by their sister company? They are not fit and proper to run a firm of solicitors if they are prepared to write to Claimant’s in this way – surely the SRA should take a look at it. They cant hind behind the insurer curtain if they want to make a profit from legal services


    October 21, 2015 at 10:45 am

    • Sam

      If they have then, yes there is, but the SRA will do absolutely nothing about large ABS’s- witness the Co-op fiasco. It was obvious that they never had the clout to tackle big business, so small and medium sized firms get picked on.

      That is one of the reasons I always opposed Alternative Business Structures- they are for all intents and purposes unregulated.



      October 21, 2015 at 10:59 am

  9. […] set of posts about the questionable practices used by insurers in dealing with claims.  Today’s post caught my eye.  It reminded me of Stephen Mayson’s concerns  about the regulatory gap, where certain […]

    • Richard Moorhead’s stuff is always worth reading. Follow him on Twitter @RichardMoorhead – blog as above.



      October 21, 2015 at 12:02 pm

  10. Under the CFA client signature area I’ve now inserted:

    In signing this agreement you authorise us to act on your behalf during any cancellation period prescribed by law. If you cancel this agreement you agree to pay us for any work done between the signature of this agreement and the cancellation.

    The possible downfall is if this provision is in turn subject to the cancellation clause, which I suspect it is. In theory (hopefully) if an insurer makes an offer that is accepted prior to the cancellation notice being given, that offer is deemed to include an offer to pay costs and so they should be recoverable.

    The answer might then be to claim any shortfall in cost from the client under the terms of the CFA. Personally I’d find that abhorrent as they’d be an innocent dupe, but I wonder what they’d say then?

    As an aside, the CII code of conduct says you cannot take advantage of a third party. If any insurer holding chartered status go down this route that might be a way to get them. Otherwise it’s wait for the Gavin Edmondson Solicitors v Haven Insurance decision.


    October 21, 2015 at 11:46 am

  11. Kerry – a comment from the “dark side” for balance.

    I agree that it is a real shame that it has come to this, but insurers/defendants have to deal with claims farmers and disreputable claimant lawyers purporting to act for so called “clients” that they have neither met or even spoken to on the phone, but have simply purchased their details in (probable) breach of the referral fee ban.

    It is not uncommon for insurers to receive letters of claim or Portal CNFs from more than one claimant firm claiming to act for the the claimant in relation to the same incident or disease.

    It’s a very murky area but it is presumed that this is due to the shoddy way in which the claimant is “farmed” in the first place and then have their details hawked around to the highest (or maybe quickest) bidder. Sadly, one of the only ways to try to establish who truly “owns” the client it seems, is to ask the client himself.

    It would not have happened in the good old days.

    ps. I cannot in any way condone or defend the pre-med offer!

    Martin Smith

    October 21, 2015 at 3:38 pm

    • Martin

      I am very grateful to you for commenting- Daniel in the Lion’s Den and all that. I do not disagree with what you say and as you know I am totally opposed to referral fees, claims farmers, hot keying and all if the other disreputable practices that some claimant organisations get up to.

      However there is a clear pattern- I have had dozens of emails and comments etc. today- of insurers contacting clients direct even though on the face of it there are solicitors on the record. Why not write to the solicitor and, where appropriate, report them?

      Incidentally it is clear from others, but also my own firm’s experience, that some matters are going on the portal twice because it is insurers who are referring to others- for an illegal referral fee or not- without the client’s knowledge or consent.

      I agree that it would not have happened in the good old days. In my view a much tougher line is needed to deal with what is a serious problem. Any hint of a referral fee should mean a prosecution before the SDT for them to adjudicate, not some mealy mouthed suggestion by an SRA spokesperson that it may be a marketing fee. Every single one of us knows a referral fee when we see one.

      Ban claims management companies. Bring in settlement agreements. Prosecute referral fee payers. Kick out insurers if they break the rules.

      Let us get some decency back.

      Once again my thanks to you for commenting.



      October 21, 2015 at 4:13 pm

      • I also work for the “dark side”, I understand the annoyance, irritation and downright disgust that some solicitors have for insurers.

        I understand that some of it is self-inflicted, with that said, most Insurers are well aware that as soon as they are made aware that the claimant has solicitors representing all correspondence goes through that solicitor or at least should.

        The issue is when we as insurers have not had that confirmation, there appear to be two types of insurers at the moment:

        1) Insurers who are genuinely trying to make sure that the solicitors representing claimants/customers actually have instruction and once identified correspond with that solicitor and make no further contact.

        2) Insurers who are trying to find out whether the claimant/customer have instruction and even if they do try to capture despite knowing solicitors have instruction.

        It is an area which I think emotion needs to be taken out, it understandably causes a lot of heat between all those involved but we need to try to remember that both were originally designed to assist the consumer in situations that they find themselves in and I appreciate that some have lost sight of this.

        In regards to the referrals fees, the issue that we are facing is that the law was badly drafted and has loopholes, the Police, recovery agents, CMCs, credit hire companies, insurers, solicitors and ABSs in one form or another are able to get referral fees, take Admiral for example just announced it took £6.2m last year according to analysts in regards to this.

        In regards to third party capture, as someone who works in an insurer, I feel that the system is broken and open to abuse, what is needed is a code of conduct in a statutory footing in which everyone knows the boundaries of what they can and are unable to do and that there will be severe penalties for abuse.

        It would also help in there was a joined up regulatory framework between the ICO, SRA and FCA, although the ICO and FCA come down quite hard on breaches of regulations which may surprise some but I have yet to see anything from the SRA in that regard. (Correct me if I am incorrect)

        The reason that third party capture (TPC) came around as we are all aware is that some within the whole industry of accident management decided to try a milk the situation as much as possible, I am not going to say which side is worse, but both sides are not innocent in this and TPC was a direct result of it.

        I do agree that once the insurer is aware that the claimant has a solicitor then they should not be making offers to them without going through the appointed solicitor, however, I feel we need to wait for the judgement in Gavin Edmondson Solicitors v Haven Insurance for clarity in a number of areas: (Ok, I am wildly optimistic that we will all get clarity but no harm in hoping right? 🙂 )

        1) Is it appropriate at any stage once a claim has been submitted for the insurer representing the Defendant to have any contact with the claimant?

        2) If so, when is it appropriate and when does this period end?

        3) Does the “right to cancel” come into the equation?

        4) If it does, when does it start, from the period of signing, submission of claim or when the Claimant returns the authority documentation?

        5) How long, if applicable is the right to cancel?

        6) Does the insurer in receipt of a CNF allowed under DPA to use the information therein to contact the claimant whether they had received the information from their client or not?

        In relation to Wolf Law Solicitors comments, I can understand where you are coming from and I sympathise with the position and your previous experience, was it not possible for yourselves to instruct an independent firm of investigators to assuage the concerns of the insurer?

        I understand that at times insurers and I have experienced this when speaking to other insurers as well. they can be difficult to put it mildly but we are both trying to do our respective jobs after all we are all human, I think sometimes people forget this and what needs to happen for all to move forward is for solicitors representing both claimant and defendant as well as insurers to actually get round the table and actually take the time to talk about this as mature adults rather than mudslinging.

        Apologies for the long winded post, I appear to have succumbed to diarrhoea of the keyboard. 🙂

        Joshua Selig

        October 21, 2015 at 5:04 pm

      • Joshua

        Many thanks for this. Will let you have a longer reply in due course, but thanks for taking the trouble to comment. Have a good weekend.



        October 23, 2015 at 5:26 pm

      • Many thanks for your long comment and I understand the points that you raise and I am not pretending that all solicitors acting for claimants have acquitted themselves and the profession well over the last 15 years or so.

        Where insurers have doubts as to whether solicitors are representing clients, why do they not ask for details of the retainer, which they are entitled to and why do they not ask the solicitors direct?

        Why do they write to the client telling them not to contact their apparent solicitors?

        As you correctly say some insurers are genuinely trying to find out if solicitors are genuinely instructed while others are attempting to capture the client even though they know that that client has instructed solicitors. It is very difficult from the tone of the letters to tell which is which.

        Some time ago one of my firm’s clients was written to a by a firm of solicitors who were very obviously paying what was then an illegal referral fee as my client had had no contact with them and had never heard their name mentioned by insurers or anyone else. I was fully aware of the situation because the client was the father of one of my solicitors!

        I agree with your comments concerning referral fees. I would make it an imprisonable offence to pay or receive an illegal referral fee and I would also make it an imprisonable offence for a solicitor to hold out that he or she is instructed knowing that to be untrue.

        Clearly these problems are two sides of the same coin as referrers are selling people to solicitors that they have never heard of.

        I would also provide that a firm of solicitors that does not physically see their client cannot charge costs to the other side. This would also help in eliminating fraud – it is much less likely that fraudulent claimants will have their case dealt with if they have to meet the lawyer in person.

        I agree with you concerning the regulatory bodies and I agree with you that as far as serious matters, such as the things we are talking about here are concerned, the SRA appears toothless and weak.

        Obviously we have now had the decision in Gavin Edmondson Solicitors v Haven Insurance but we have not had the clarity that we all sought.

        For what it is worth my answers to your numbered questions would be:-

        1. No
        2. Not applicable
        3. No
        4. Not applicable
        5. Not applicable
        6. No

        However I would allow insurers to be entitled, on submission of the Claim Notification Form, to know the details of the retainer between the claimant and the solicitor, including the date of the retainer, the nature of the retainer – CFA or No Win Lower Fee or whatever – whether the firm has physically seen the client and if so on what date together with a copy of the Notice of the Right to Cancel and the date it was given.

        No honest solicitor would have a problem with this and it would make all solicitors put the information on the line and if they had not actually been instructed then this would involve a deliberate lie to the court as there should be a certificate with the CNF saying that the solicitor has provided this information and that it is true.

        Such a deliberate lie would allow the claim to be struck out as an abuse of process, or under Section 57 of the Courts and Criminal Justice Act 2015 and will be contempt of court and a criminal offence and thus would side step the non-enforcement by the SRA of the rules in this area.

        I also agree that claimants and defendants need to get round a table and sort these matters out.

        One of the saddest things is that there is now a clear claimant side and a clear defendant side and there are relevant few defendant firms and they are not seen as part of the profession generally.

        This is in marked contrast to when I started work when there were hundreds of firms doing defence work and every firm had the prospect of getting such work. That inevitably drove behaviour as firms hoping to get defence work would not behave in the way that we have identified in your comment and my reply.

        Many thanks once again for your comment.



        January 25, 2016 at 10:37 am

    • Martin

      I dont see why you need to check who “owns” the Claimant? You can simply reject the CNF or accept both and let the solicitors know, it is then for them to battle it out and see who is representing or if both have been instructed then speak to the client. There is no Stage 1 to pay and no solicitor wants to act for a client already represented so it shouldn’t affect the insurer in any way. I fail to see why you need to go the trouble of writing to the client, speaking to them and offering them money upfront, just to check who “owns” them!?

      As Kerry says and certainly in my own personal experience, most duplicate CNF’s are from insurer ABS’ or pet law firms that they have referred/recommended or whatever. The common theme appears to be, the client didn’t even know he’d instructed anyone else! I am therefore sceptical as to who the true culprits are in all this.

      We need to remember that insurers represent us all, the general public- most are owned by us in fact. They are not businesses for the sole purpose of making profit, rather, we allow it as the public so that they can function. What they should be doing is representing our best interests and that means not taking advantage of individuals or injured victims for the sole purpose of making more profit. They should make profit, agreed, but not by taking advantage or the public that they are there to represent.

      We all pay into a pot to protect us in the event we are injured, our car is damaged and we need a hire car to take the kids to school or we need our nice new BMW repairing properly etc… etc… the profit they make should be a bi-product – not the means to an end. The Defendant side need to stop this perception that they are businesses and have a god given right to make a profit at all costs and not have to pay out.

      Insurers/banks should count yourselves lucky that car insurance is compulsory in this country and that you have all been bailed out by joe public despite the fact that you have missold him PPI, fixed exchange rates, overpaid bonuses and brought his country to its knees through greed and corruption. Yet if he tries to make a claim for injury or dare hire a replacement car- he’s the biggest fraudster in Europe……..!!


      October 26, 2015 at 2:31 pm

      • Martin

        Sam makes what I consider to be some excellent point but I am sure that you may have a slightly different take!



        October 26, 2015 at 2:36 pm








  19. […] Ever seen worse th>n more>n? Insurers at it again (6) […]

  20. […] Nevertheless, insurers continue to engage in making pre-medical offers, encouraging claimants to settle claims without the benefit of any medical report or evidence to advise them on the extent of their injuries and any potential need for treatment. Insurers continue to contact claimants directly even when they have instructed solicitors – an example of this was recently highlighted by Kerry Underwood here. […]

    • Many thanks.


      October 29, 2015 at 10:37 am

    • I think insurers probably have questions as to whether a medical examination (some lasting a few minutes) is a method to validate an injury.

      Paul Smith

      November 4, 2015 at 8:52 am

      • Paul

        I agree. There are virtually fool proof ways of testing soft tissue injuries – I subjected myself to one some years ago – but insurers do not seem interested and claimants certainly aren’t.



        November 4, 2015 at 9:51 am



  23. My son, who is on the Autistic spectrum has received an identical letter as the result of a car accident in March.
    The accident has been dealt with ,not his fault but he has been given an appointment to see a doctor for an injury examination at the end of July(4 months later).
    I don’t know any details as he doesn’t always share with me.
    Any advice? Liz B

    Liz Bennett

    July 12, 2019 at 12:02 pm

    • Your son should take it to his solicitors and refer them to my blogs. If your son gives permission I will write a fresh blog about it.


      July 12, 2019 at 5:26 pm

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