As we come to the close of the year and our final 2024 issue of CCTA Magazine, this is an ideal opportunity to reflect on the developments from the past year.

Consumer Duty

Any review of the year has to include the Consumer Duty. Everyone started the year with one eye on the mid-year anniversary. With so much uncertainty, the CCTA stepped in with guidance papers and events to draw on the insights we could bring back from our discussions with the FCA.

It became clear that it was critical that firms share experience and make the best case possible when challenged by the regulator. Throughout this year, we have looked at the exchange of information between brokers and lenders. Lenders undertook reviews like fair value assessments. The writing of the Board report completed this first stage.

However, we know this is a journey, not a destination. It is also a journey that will continue for the foreseeable future.

Access to credit

Access to credit has long been one of our core campaigns. It was why lenders founded our association over 130 years ago. We started the year by discussing the fall in the credit supply with the FCA. Later, the regulators reached out to many of our high-cost members. We were involved in independent research that showed the scale of the issue. As we come towards the year’s close, there is more focus on financial inclusion than ever. The FCA now must “have regard” for financial inclusion in everything it does.

Recent Court of Appeal ruling

Elsewhere, we all had an unpleasant surprise as the Court of Appeal altered our understanding of the relationship between lenders, brokers and consumers. Car finance providers have moved quickly to respond. However, we are now working on a solution that might involve a review by the Supreme Court. The FCA will most definitely need to get more involved to minimise disruption.

As I write this, we still have a few weeks left in 2024. Maybe it is too early to draw a line under the year.

Regulatory changes

Recently, the Chancellor discussed some opportunities in her Mansion House speech.

Earlier in the year, we received some positive indications when the Financial Ombudsman Service (FOS) proposed charging claims management companies (CMCs) and legal firms a case fee. For us, it was another step forward. We have been working on this change for several years.

We are also in the early stages of a consultation on the reform of the FOS.

If that is not enough, the Treasury has undertaken work to look at new regulatory changes. The long awaited regulation of Buy-Now Pay-Later is moving down the road.

Consumer Credit Act reform

The election had brought the conversation about reform of the Consumer Credit Act (CCA) to a close, but as the year ends, those talks have restarted. We have actively lobbied for changes that balance updating the system and regulatory certainty.

Smaller lenders often find themselves disproportionately burdened by regulations designed with larger institutions in mind. However, just as worrying is when the regulator leaves us to work through the outcomes-based regulation puzzle.

We have made significant strides in ensuring that policymakers hear and understand the unique perspectives of our members. There are more active discussions than ever before, which is a testament to our team. It has been great to have my colleagues, Naveed and Lucy, working with me.

We aim to ensure that any reforms enable smaller lenders to continue playing their role in providing access to credit for those who need it most.

We have made significant strides in ensuring that policymakers hear and understand the unique perspectives of our members. There are more active discussions than ever before, which is a testament to our team.

CCTA service improvements

Alongside our policy and advisory work, the CCTA team has been working to improve our services. We know that it is essential that we make the most of the resources provided by our members.

We have continued the roll out of CCTA Academy to new firms in 2024. We have a long history of providing specialist training and we are pleased continue this with our new approach.

Developing the CCTA team

Our most recent change has seen us recognise the need for additional membership support, and I welcome Sarah Garratt as Membership Manager. This is an expanded role built on the work of Brian Corke, who is now retiring. The retention of our existing members remains very high, and I believe that this is partly due to the excellent relationships with our membership.

I also wanted to recognise the work of another colleague, Phill Harding. It is appropriate that I use the magazine to state this because he has been quietly improving all of our communications over the last couple of years. This magazine looks very different to the one he inherited. Phill has been moderinising our brand and looking to improve our operations so it makes sense that he becomes our Head of Operations & Brand. He takes that next step with my thanks for his help.

In conclusion

Lastly, many thanks to all of our members for their support this year. Please keep an eye out for the 2024 edition of ‘CCTA: Year in Review’, which will provide a further summary of the activity we have undertaken on behalf of members this year.