Away from the drama at Westminster, Andrew Bailey delivered an important and revealing speech to the BBA retail banking conference on Thursday (the last such to a BBA conference following the body’s official integrated into UK Finance).

The speech was notable for its intellectual breadth and insight into banking models, perhaps unsurprising given the speaker’s record of service in the Bank of England and the PRA.

There were two passages of particular note to the credit industry.

First, on the High Cost Credit review, Bailey said this:

“Last November we issued a Call for Input covering high cost products, overdrafts, the high-cost credit short-term price cap and report and multiple such borrowing.  We are looking at all high-cost products to build a full picture of how these are used, whether they cause harm and, if so, to which consumers.  We will then be able to decide if we need to intervene further […] We are also reviewing the price cap on short-term high cost loans which came in force in January 2015.  We intend to publish our findings on this over the summer.”

So at least we have a vague date, if not clarity over the regulator’s intentions.

There had been speculation as to the latter in the media in recent weeks — that the payday cap might even be raised.  The FCA seemingly scotched that rumour, a spokesman responding “This does not reflect our position” and reiterating that the FCA intends to publish a feedback statement “later in the summer” setting out next steps in the review.  These are expected to be FCA proposals for consultation.

The second passage of note addressed the crucial question of access to credit as a public policy issue:

“There is also an issue around access to credit, which for me is at the heart of our interest in high cost credit.  Put simply, it would not be an acceptable outcome to cut consumers off from access to credit when they have a justifiable need for credit, for instance to smooth erratic or lumpy income.  Now, before the headlines get written that I am justifying current household debt levels, that is not the point I am making.  I am not talking about that subject today.  Put simply, there is a point about access to credit which is a broader public policy question, and needs to be considered as such.”

During questions, Bailey highlighted the particular threat of a rise in illegal lending if legal sources were to be restricted by regulatory action.

These comments are significant. For one, they reveal the combination of pressures that bear down on any authority charged with balancing consumer demand for credit on the one hand and debt campaigners’ distaste for it on the other.  But, more significantly, it is the regulator putting down a marker for maintaining access in spite of the flak he will inevitably receive if and when he does.

CCTA has consistently been banging the drum on ‘access’ in meetings with the FCA, so it is heartening to see the message getting through. And there’ll be no let up: from summer into autumn, we will be holding a series of parliamentary and industry events to impress upon MPs the need to hold the FCA to its word.

There is an additional point we will be pressing — access is just as important for businesses as it is for consumers: if the scale and cost of FCA regulation make market participation unviable for SME credit businesses, provision becomes monolithic and the consumer suffers from less choice and less diversity.

The debt campaigners want to see the opposite. For them, fewer credit businesses means less indebtedness. There are always more arguments to be won.