Industry Insights

The FCA introduced changes to the Consumer Credit Source Book from 4 November 2024. For consumer credit firms, the important changes to review are: CONC 1.1 – Application and purpose CONC APP 1.2 – Total charge for credit rules for other agreements CONC 5.2A – Creditworthiness assessment CONC 6.7 – Post contract: business practices CONC 7.2 – Clear, effective and …

The recent (and largely unsuccessful) increase in claims against motor finance lenders relating to a vehicle’s previous keeper history has brought into focus what checks (if any) lenders need to make before entering into a motor finance agreement. In this article, we consider whether there is a need to make enquiries about any outstanding recalls before supplying a vehicle. The …

The Court of Appeal’s decision in Johnson v FirstRand Bank Limited (London Branch) [2024] EWCA Civ 1282 came as a considerable surprise to the motor finance industry (and many other financial services industries). This short article considers the decision and what will happen next. The facts Each claim involved a consumer visiting a dealer, selecting a vehicle and wanting finance. …

Brandon Wallace, Senior Product Manager at financial data intelligence company Bud, explains why, contrary to misconceptions, use of open banking data in the affordability assessment process can help lenders increase approvals without taking on extra risk. It’s a common misconception in the lending industry that using open banking data in lending processes will lead to an increase in declines. This …

I had the pleasure of joining a panel on access to responsible credit at the recent CCTA Conference, alongside experts on this issue from government and industry. It was great to hear the views and suggestions of my fellow panellists, in particular the importance of collaboration and the potential for partnerships between mainstream and alternative lenders. As I said at …

In the UK collections industry, security, efficiency, and customer trust are essential. As digital payments become the norm, financial service companies face a unique set of challenges, including managing recurring payments securely, reducing operational costs, and minimising fraud risks. One technology proving highly valuable in this landscape is network tokenisation – the replacement of traditional card details with unique, merchant-specific …

Ensuring customers have an appropriate degree of protection is central to the FCAs mission. Under the Vulnerable Customer Guidance (FG21/1), the FCA expects vulnerable customers to receive outcomes equal to the treatment of other customers. Treatment must be consistent and fair across the end-to-end product and customer lifecycle. The FCA’s focus on vulnerability continues to sharpen. In March 2024, they …

Amid continued economic uncertainty and an unexpected inflation rise to 3.9% in January, many UK residents are turning to borrowing to help manage their money and make ends meet. In fact, our research found that one in five UK adults – approximately 11 million people – now consider themselves financially vulnerable and at risk of harm due to their personal …

In the competitive landscape of alternative lending, trust is not merely an asset; it is a necessity. As consumers increasingly seek clarity and fairness, lenders must step up their game, creating a transparent environment where borrowers feel informed and secure in their decisions. The key to achieving this lies in the integration of effective decision systems that prioritise transparency, ultimately …

The Bankruptcy and Diligence (Scotland) Bill was passed by the Scottish Parliament on 6 June 2024. It is not yet known when it will come into force, but an important milestone has been passed. The Bill brings into force an important new measure in debt recovery in Scotland, namely the introduction of a Mental Health Moratorium. Separate regulations as to …

“Complaints! It’s easy, right?” As industry representatives, we often hear this. At its core, handling complaints is about addressing customer needs and restoring faith in the brand, epitomising ownership. However, to keep it “easy,” you need robust planning and implementation, which is anything but easy. Drawing from my experience, this article outlines a strategic framework to help you navigate the …

n the ever-evolving landscape of cyberspace, legal disputes can arise where the identity of the alleged wrongdoers are shrouded in anonymity. These disputes present unique challenges for the traditional legal frameworks, particularly determining accountability. A case that has explored this area further is Mooij -v- Persons Unknown. The judgment not only underscores the complexities of holding unidentifiable persons accountable but …