In the shadows of the financial advice world, where trust should be sacred and transparency non-negotiable, a quiet reckoning has begun. One of the UK’s largest and most influential advice firms, St. James’s Place (SJP), has finally broken rank and spoken out. Not about success. Not about service. But about failure.
Let’s call it what it is: A stain on our industry.
Tony Müdd, SJP’s Divisional Director, didn’t mince words when he said:
“Inflating a protection premium purely to give the adviser a higher payout has always been unethical. It borders on a stain on our industry.”
Finally, a confession. Finally, someone from the inside stepping forward. Not with excuses. But with truth.
The Hidden Cost of Protection
When clients pay for protection — life insurance, critical illness, income protection — they believe they’re safeguarding their future. But what if the price they pay isn’t just for cover, but for an undisclosed commission hidden inside a loaded premium? What if the policy that brings peace of mind to a family also pads an adviser’s wallet — in secret?
This isn’t about hard-working advisers earning fair pay. This is about a system that, for too long, has enabled policy churning, non-disclosure, and the exploitation of trust.
Let’s break it down:
- Clients weren’t told they could get a lower premium.
- They weren’t told how much commission was being taken.
- They weren’t told that switching a policy could mean losing valuable benefits.
- They weren’t told the truth.
And when they were told “there’s no fee”, they believed they were getting free advice. But nothing is free. It just wasn’t disclosed.
Is Churning a Problem at SJP?
Let’s be honest: when your entire remuneration for protection comes from upfront commission, and the only way to get paid again is to replace a policy, churning becomes more than a possibility — it becomes an incentive.
SJP advisers are restricted. They sell from a panel. They are paid via commission only. There is no fee-based option for clients. No ability to say: “I’ll pay a flat fee instead.”
This model creates conditions where advisers may feel pushed to find reasons to rewrite policies, even when the client’s existing cover is still suitable. That’s churn. And it’s costly.
Costly in trust. Costly in money. Costly in lost benefits.
The Supreme Court Has Spoken
Recently, the UK Supreme Court ruled that undisclosed commissions in motor finance agreements can create an “unfair relationship” under consumer law. Why? Because the client wasn’t told they were being charged more just to pay the salesperson.
That ruling isn’t just about car loans. It’s about principles. Transparency. Trust. Fiduciary responsibility.
If this applies to a car dealership, how much more should it apply to financial advisers?
The parallels to the protection market are crystal clear:
- Loaded premiums = higher cost for the client.
- Undisclosed commissions = hidden incentive for the adviser.
- No alternative offered = limited client choice.
This is the environment SJP operated in. And while the company now calls for reform, let’s not forget: it helped build the house.
Where Are the Disclosures?
In SJP’s glossy annual reports, you’ll find plenty of numbers. Revenue lines. Growth stats. Fee structures for investments.
But what you won’t find is a breakdown of the commission SJP earns from protection sales. No disclosure of:
- How much commission is paid.
- What percentage of premiums it represents.
- How many policies were replaced.
- How many were loaded.
Omissions speak volumes. And for clients who thought their premiums were purely about cover, the silence is deafening.
Not Just Legal — Ethical
Some defenders of the status quo argue: “But it was legal.”
Yes, it was legal. Just like it was legal to sell interest-only mortgages to pensioners or payment protection insurance with loans. And look where that got us.
What’s legal isn’t always what’s right.
As Tony Müdd himself said:
“It may have been legal, but it was never right.”
And that’s where the Academy of Life Planning takes its stand.
We are not here to demonise protection. We believe in it. We are not here to dismantle advice. We believe in it. But we are here to demand transparency, client choice, and ethical remuneration.
The Alternative Exists
At the Academy, we and our members operate differently:
- Many offer no-load protection advice, where the client pays a fixed fee and receives a commission-free policy.
- Some rebate commission against their advice fee, ensuring the client gets value for money.
- Others refer to independent brokers like LifeSearch, with agreed commission rebates passed directly to the client.
The result? Clients save thousands over the life of a policy. And they make decisions from a place of clarity, not confusion.
This is not theory. This is real. This is happening now. And it’s open to all.
To the Critics Crying “AI” and “Tone”
Yes, this message is direct. It’s urgent. It’s uncompromising.
And it needs to be.
Because if advisers are more offended by tone than by clients paying inflated premiums, we have a bigger problem than commission. We have a problem of conscience.
And to those saying “It reads like AI”: The facts are human. The consequences are real. The industry is on notice.
This isn’t clickbait. This is a call for accountability.
The Path Forward
The FCA’s protection market study is underway. The rules are tightening. The courts are listening. Consumers are waking up.
Now is the moment for reform. Not in whispered promises. Not in future press releases. But in action.
Advisers must:
- Disclose their commission.
- Offer alternatives.
- Explain premium differences.
- Act in the client’s best interest, not their own.
We’ve Seen This Movie Before
The financial services industry has a habit of apologising after the fact:
- After endowments.
- After PPI.
- After interest-only.
Let’s not wait until protection becomes the next scandal. Let’s fix it now.
Because a premium shouldn’t pad pockets. It should protect families.
Let’s take the stain out of our industry. Let’s clean up. Let’s do better.
See previous articles:
Transparency Over Commission: Why the Academy of Life Planning Supports a Fairer Protection Market, and
Your Money or Your Life: The Hidden Cost of “Protection”.
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Academy of Life Planning 
As the quoted individual in this ridiculous article full of more errors than monkeys with typewriters trying to compose the works of Shakespeare I will simply say trying to take the moral high ground through deliberate mis-information and mis-direction is about as low as it gets
Tony Mudd
Response to Tony Müdd
Tony, thank you for engaging — and for confirming that this conversation is one that needs to be had.
Your original remarks, published and publicly attributed to you in Health & Protection (28 July 2022), described the practice of loaded premiums as “bordering on a stain on our industry.” I quoted you accurately and in full context. If you now take issue with your own published position, perhaps the industry deserves an update from you directly.
This article does not attack individuals — it challenges opaque systems. It asks difficult questions about historic practices, consumer harm, and regulatory risk. The same questions the FCA is now formally investigating, and that the Supreme Court has brought to the fore in other sectors.
If my tone appears direct, it is because the stakes — for consumer trust, for adviser integrity, and for fair value — are too high for soft language. I will always welcome respectful dialogue and constructive challenge. But I won’t be intimidated into silence by deflection or insult.
If we’re truly committed to reform, let’s keep the conversation focused on transparency, not theatrics.
Warm regards,
Steve Conley
Founder, Academy of Life Planning
Steve
Lets be clear if you felt I was trying to intimidate you then I got the tone wrong. I was simply pointing out, as you must know the article had errors and was misleading. That I can forgive but I take exception to you deliberately setting out to suggest SJP engage in a practice, Loaded premiums, that I have written at length on being poor practise and campaigned against for some time, that SJP never been party too.
Kind regards
Tony Mudd
Divisional Director, Development & Technical Consultancy
M. +44 (0) 7747 568038
T. +44 (0) 1285 878268
E. tony.mudd@sjp.co.uktony.mudd@sjp.co.uk
W. sjp.co.ukhttps://www.sjp.co.uk/
St. James’s Place
1 Tetbury Road,
Cirencester, GL7 1FP
Tony,
Thank you for your clarification — and I appreciate your acknowledgment regarding tone.
To be clear, I have no intention of misrepresenting you or SJP. In fact, I quoted you directly and accurately from a respected trade source (Health & Protection, July 2022), where your remarks on loaded premiums were unequivocal. I referenced your words precisely because they reflect a call for reform — a call I support.
Nowhere did I state that SJP currently engages in the practice of loading premiums. The article explores broader systemic issues — including historic opacity, commission-driven models, and regulator concern — all of which are now the subject of FCA investigation and industry reflection.
If there is more you’d like to say on behalf of SJP, I would encourage you to provide a public clarification via the trade press, where your position can be fully represented and considered in its professional context.
My blog is a platform for thought leadership and accountability — not personal dispute — and I will always seek to ensure it remains respectful and grounded in fact.
Warm regards,
Steve Conley
Founder, Academy of Life Planning
As someone with no vested interests in either direction – this article definitely comes across as painting SJP as a firm who engages in the bad practice that is being highlighted and I had assumed that was the case. Steve – you may not have directly said this, but surely you aren’t blind to the fact that this is how the article comes across.
Tony Mudd appears to have clarified that SJP in fact do not do this, so to me this seems to somewhat discredit / devalue your whole article and does absolutely nothing to promote trust or integrity. I’d also ask – what is the relevance of SJP to this article, other than quoting Tony Mudd’s comments?
Response to Anonymous Comment:
Thank you for taking the time to comment. Since you’ve raised some important points, I’d like to clarify a few things for you — and for any reader who may share your perspective.
The article accurately quotes Tony Müdd, Divisional Director at St. James’s Place, from a published interview in Health & Protection (28 July 2022). In that interview, he referred to the practice of loaded premiums as “bordering on a stain on our industry.” I have linked directly to that article for full context and transparency.
Nowhere in my article do I state that SJP currently engages in the practice of loading premiums. What I have done is explore systemic risks and historical incentive structures in the protection market — many of which the FCA is now formally investigating. These are not accusations, but reflections on a system that is finally being scrutinised.
If the article led readers to infer that SJP could be part of a wider culture of opacity or conflicted incentives, that’s a separate issue — one that speaks to how embedded industry structures shape perceptions, not the article’s factual content.
As for the relevance of including Tony Müdd: quoting a senior industry figure who has spoken out publicly on these issues is not only fair — it’s responsible. His leadership role makes his perspective highly relevant to this conversation.
And finally, on the subject of trust and integrity:
We all benefit when people engage openly, with their names and credentials visible. Anonymous commentary questioning another’s integrity — especially when quoting accurate, sourced material — contributes little to honest debate. Transparency matters here, too.
Warm regards,
Steve Conley
Founder, Academy of Life Planning
For transparency: based on the language, IP trace, and timing of the anonymous comment submitted, it appears to have been authored by someone within St. James’s Place, potentially a member of the internal operations or PR team.
If this is the case, I would encourage SJP to address its public position on protection market ethics through formal trade channels rather than through unnamed blog comments.
This ensures clarity, accountability, and respect for the wider professional community engaged in this important dialogue.