This is your opportunity to influence the areas of work carried out by the CMA for the next 2 years.

 

Please complete the form on the following link. It is self explanatory for the first 4 questions. To complete questions 5 & 6 please use our example below.

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Form here

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Question

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Q5.   Do you agree with the overall direction and themes of focus for the CMA set out in the 2021/22 draft Annual Plan?

 

(Add your comments in the box after the question.

Include something similar to our first 2 paragraphs as per below then add an example as we have.)

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(Answer)

I agree with the plan in the most part, however I would like to see it recognise that for some Service Industries, such as Holiday Caravan Parks, once you are locked into standard consumer contract (which for new caravan purchases is a minimum of 10 years) you are forced by the use of unfair trading practices or contract terms open to misinterpretation by companies, to purchase all additional and essential services from the Holiday Park Company.

 

These come at a grossly inflated marked up cost as a result of being refused the option of purchasing direct from the traders or suppliers. You have to pay direct through the Holiday Park Company and if you question this as an unfair practice you are threatened with the removal of your caravan at a significant cost, causing a substantial loss of value for your caravan.

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(Inc Your Example)

For example we asked to purchase decking direct from the suppliers, but were refused and had to buy through the Holiday Park Company at a mark up of over 100%. When contacting the suppliers direct they refused to give quotes stating that we have to have permission from the Holiday Parks for them to quote for business on the park. It is clear that there is collusion between decking suppliers who have contracts with Holiday Park companies. The decking supply companies see it as detrimental to their own business if they do not adhere strictly to doing business through the park companies, as there is a risk they will lose large contracts to rival suppliers.

 

The result was we had no option but to purchase at a grossly inflated price through the park, with no choice of product and no way of negotiating a price. Pay it or leave it, if you don’t like it, leave and take your caravan with you, here is the bill for disconnection and moving it to the gate.

 

Cost of Decking through Holiday Park Company £7k

Cost direct from supplier £3.5k

Mark up percentage 100%

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 (Your examples should relate to any service that you have to purchase through the park where you know if you were allowed to arrange yourself it would be considerably cheaper. Include the price you had to pay and what you consider the price would have been had you been able to shop around:

Gas Servicing

Insurance

Electrical Service

Decking Supplies

Drain Downs

Private Sales Commissions

Renting Out Services

General Maintenance

Or any other service you had to pay for via the Parks Company

You may also wish to include reference to any terms in your agreements that prevent you from setting up group Facebook Group pages or commenting on social media regarding the park, as a manner of controlling negative views, preventing a true market picture of the company and dividing owners so they can not make any challenges to unfair practices). 

 

 

Q6. Are there any changes that you think we should make to our main themes for 2021/22?

The themes are: * Protecting consumers and driving recovery during and after the pandemic, with a particular focus on: - protecting the vulnerable from breaches of competition and consumer protection laws and poorly functioning markets - Supporting the UK economy by fostering competition to promote innovation, productivity and growth 2021/22 * Taking our place as a global competition and consumer protection authority after the EU Exit Transition Period * Fostering effective competition in digital markets * Supporting the transition to low a carbon economy

 

(Add your comments in the box after the question.

Include something very similar to our example.

Also include the fact that you have been refused any refunds or if you have been threatened for simply asking for a refund or if you believe they have altered your annual invoice to avoid refunding you the VAT element of your fees).

 

(Answer)

Yes, we would like to see the definition of vulnerable extended to take into account vulnerability created as a result of being locked into a consumer contract where all additional and essential services ancillary to the core terms of the contract can be controlled by one company, either using poorly worded consumer contract terms or unfair trading practices.

 

Perhaps having a prominent term added to Holiday Park Companies standard consumer contracts that give the object or effect of making it clear to both the company and consumer, that the consumer has the right to shop around for all additional and essential services commonly associated with the normal use of their caravan. Further that that the termination or threat of termination of a contract resulting from a consumer seeking to pursue their consumer rights would be subject of investigation and if necessary prosecution by the authorities.

 

 

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