Industry Thoughts

I recently received a notification on social media that I had passed my second anniversary as Chief Executive of the Consumer Credit Trade Association. It came as a little bit of a surprise as the time just seems to have flown by. Looking back, when I took over from Greg Stevens, it was important that we continued his work of advocating on behalf of our members. The CCTA’s mission for over a century has been to protect access to credit and understand the benefits that credit can deliver. Our vision has long been to ensure responsible credit for all and that has been at the heart of our conversations. I am the latest in a line of CEOs that has made that part of my mantra. We also wanted to add value, so we took the existing work of the CCTA and added new elements. Over the last two years, we have established further channels of communication. We have ongoing discussions with the Financial Conduct Authority, Financial Ombudsman Service and HM Treasury. Through these discussions, we have been able to talk about a range of issues. We have made clear that members need more information to help with the implementation of Consumer Duty. We have tried to explain the implications of the focus on affordability. There are many other issues that we have placed on the agenda. The CCTA’s mission for over a century has been to protect access to credit and understand the benefits that credit can deliver It has been interesting how during this economic downturn, the knee-jerk reaction of some is to say that we need to switch off the supply of credit. I agree that consumer credit is not always the answer. However, there are still cars that need to be bought to get people to work. Families have back-to-school costs. These are essentials and consumer credit plays its part. So, in much of our advocacy work over the last two years, we have been explaining how modern credit products can facilitate those bigger spends as well as managing cash flow. Credit is not the answer for dealing with longer-term financial issues with levels of uncertainty. It can be used to manage those temporary, expected, and unexpected peaks and troughs in finances. It can be used to buy those items that will make life easier or open up new opportunities, such as getting to a job that is not accessible through public transport. It has been interesting to make these arguments and represent CCTA members. One of the advantages of being a member of a trade association that covers some inter-connected sectors is that you can draw from the experience of one and use it in another. For example, our experience with complaints places us in a better position when the attention of claims firms move to another part of our membership. We can see some issues emerging that might be future problems for others. I confess that I need to learn and understand more of …

As we enter 2023, there has been a discernible shift in the conversation around the UK’s cost-of-living crisis. Increasingly, the focus is on a subject we know all too well: household debt. From debt advice charity StepChange warning it will take years for Christmas borrowing to be repaid, to NatWest announcing it will extend the amount of time customers have to repay unsecured loans or overdrafts by six months – lenders and collection businesses are being forced to ask some tough questions. As Chris Leslie, CEO of Credit Services Association (CSA) puts it: “The squeeze on available income after accounting for essential expenditure is still set to get worse in the coming year – which in turn will raise the number of households in deficit budgets and make the collections challenge harder still.” At Lantern, we’ve been reflecting on the trends we’ve seen over the past year and how we should approach the challenges ahead. We’ve distilled these reflections into three ‘must adopt’ strategies for lenders and debt collection businesses. STRATEGY #1 (LENDERS) Improve ‘up-stream’ care of vulnerable customers Some lenders have a mixed record when it comes to effectively categorising and looking after customers who are truly vulnerable and unable to pay. The temptation has often been to offload non-performing debts to collection businesses – but in the current crisis, they should consider some tough questions around their duty of care. Sonex Financial (part of the Lantern Group) – a specialist white label service, helping lenders look after vulnerable customers in a bespoke fashion, are seeing first-hand lenders’ response to the cost-of-living crisis. According to CEO Stefan Russell: “It’s crucial for conversations to be held by the right people, who can empathise with the difficulties faced by customers in today’s climate. Having a team who understand and can relate to the challenges is important for building trust and long-term relationships with customers, to provide a caring, effective and compassionate customer service for as long as it takes”. STRATEGY #2 (COLLECTION BUSINESSES) Prepare to be flexible and patient on repayments The cost-of-living crisis has been part of our day-to-day conversations with customers for the past year. Overall, we’re not seeing significant reductions in repayments – with customers choosing to reduce spending in other areas and preferring to maintain their existing, affordable repayment plans. From Lantern’s perspective, this can be explained by the fact that many of our customers are already in vulnerable circumstances, with repayment plans forming only a small proportion of their net disposable income. These customers are naturally resilient when it comes to cutting back household spending, generally used to very tight budgeting in their day to day life. Across the wider collections industry, there are stories of fewer payments in full or settlements, as customers choose to hold back on using savings accrued during the pandemic. This is also potentially an indication of a new kind of customer experiencing debt for the first time – one that should push lenders and collectors to ask the honest question: …

Customers with existing credit (whether loans, credit cards or hire purchase deals) are frequently targeted with tempting promotions for 0% introductory deals or personal loans with lower APRs than they currently pay. Debt consolidation solutions can be hugely beneficial to some customers who struggle with their monthly debt repayments, a situation likely to worsen if the pressures on the cost-of-living increase. However, whilst consolidating debts can make monthly budgeting easier or may mean a customer pays lower APRs, these are often accompanied by a significant increase in the overall amount the customer repays. It’s not unreasonable to assume, particularly as the regulatory landscape continues to evolve, that the FCA may expect improvements in customer journeys and increased clarity in the information presented to customers. This not only includes the monetary benefits of consolidation, such as a lower monthly repayment or a lower APR, but also the salient disadvantage of how much larger a customer’s overall indebtedness may become. It would not be ‘disclosure for disclosure’s sake’, but an evolving step in helping the customer work out whether any proposed consolidation may be in their best interests. At first glance, it would be easy to assume this is a straightforward decision for a customer in problem-debt. However, they might benefit more from seeking debt-advice rather than simply re-borrowing. If the FCA’s expectations do evolve in this area, the crux is likely to be on achieving balance at all stages of the customer journey. This includes ensuring the customer is aware of the risks of consolidation whilst not being actively discouraged from something which has the potential to make monthly budgeting easier. APPROACHING LENDERS If a customer approaches a lender directly, for example when seeking an unsecured personal loan from their current account provider, it should be a reasonable expectation that the lender sets out an individual, tailored quotation, including the overall cost of servicing any new debt which the customer may enter, and how the overall cost of the new borrowing compares with the customer’s existing debt. Doing this will never be straightforward, as the lender would have to make a series of assumptions, including on the stability of future repayments a customer may make on their existing borrowing, and on the stability of future interest rates in any existing variable-rate credit products. This information, even if only illustrative, would help the customer make an informed choice about whether to enter the new borrowing to repay existing credit, retain their existing debt, or seek alternative debt-solutions. The provision of information at this level could be a future expectation from the regulator, and one which firms should consider now. Frequently, customers do not make a direct approach to a lender – at least not without having first used price-comparison platforms, eligibility-checking services, or other more traditional forms of credit brokers. By the time a customer submits a ‘final’ application (i.e. a hard-credit search in the anticipation of entering into a specific regulated credit agreement), they could have already gone through a series …

Consumers in the UK are facing increasing financial pressure amidst the rising cost of living. Inflation hit 10.1% in the twelve months to January 2022, whilst the Bank of England raising base rates to 4.0% has significantly increased the cost of borrowing money. Unsurprisingly, people are feeling the impact, with our latest Consumer Pulse study showing three quarters of UK consumers are reducing spending to help them cope, whilst nearly four in ten (39%) are building up savings to safeguard themselves. In the face of economic uncertainty, it’s crucial for credit providers to be able to better identify and serve financially vulnerable customers. And with new regulation from the FCA coming into effect this year in the form of the Consumer Duty, which aims to set higher standards of consumer protection across financial services, affordability assessments based on a robust and holistic picture of an individual’s financial situation can play a major role in helping to deliver the right outcomes. IDENTIFYING VULNERABLE CUSTOMERS Our analysis here at TransUnion suggests that 12 million consumers now spend everything they earn (with £0 disposable income at the end of the month) up from 8 million in December 2021. So, to help protect consumers and manage their customer base better, credit providers need to be taking a proactive approach to identifying financially vulnerable customers and implementing appropriate affordability checks. The view on cost of living is crucial when undertaking an affordability assessment. It’s important that affordability screening reveals not a general trend but an individual-level susceptibility to stress and economic changes, such as steeply increasing energy prices or a fixed rate mortgage ending – which will likely have a significant impact on consumers in the current financial climate. It’s also paramount that the cost of living view includes different expenditure categories, such as council tax, energy, water, media services, home insurance, car insurance, commuting and food. This can help lenders get detailed insights into a consumer’s financial position and make more informed and sustainable decisions. EMPOWERING CONSUMERS In addition, by accessing an individual’s bank account directly via Open Banking – subject to the consumer’s consent – credit providers can obtain a granular picture of income and expenditure, complementing the traditional credit reference data. This helps finance providers to make lending decisions that are tailored to the needs of each individual, whilst also simplifying the process for the consumer and reducing the need for manually providing bank statements and other documentation. Open Banking can also help with stress testing and identifying where consumers may experience an unexpected drop in income that could have a significant impact on their financial stability and ability to make repayments on their loans or credit agreements. Credit education tools, underpinned by Open Banking technology, that help consumers to understand their credit information and how it’s being used by lenders, are also a valuable support. These tools empower people to monitor and manage their financial standing and we’ve seen, with TransUnion’s solution which is used by many leading banks, that this …

The price and value of regulated financial services products has long been in the FCA’s spotlight. The Consumer Duty is strengthening the FCA’s focus in this area. While the FCA already has powers to regulate certain aspects of pricing for financial products and services, its primary focus has been around consumer protection and market integrity. With its concurrent competition objective and with its view and interpretation of consumer protection arguably widening as part of the Duty, the price and value outcome is raising the stakes. It’s clear that many within the financial services sector are struggling to gain traction with evidencing both the rationale and justification of their pricing and value strategies. Our most recent webinar in February 2023 highlighted that 60% of respondents found that the price and value outcome was the single most difficult outcome to effectively evidence. This isn’t a surprise given just how difficult it can be to firstly, define fair value and secondly, to connect all of the dots together to paint a picture as to what fair value means, given it will be a component of both financial and non-financial measures and metrics. So what do firms need to do to evaluate price and value in a Consumer Duty world? LOOKING BACK TO LOOK FORWARDS According to the FCA, price is the amount that consumers pay for a financial product or service, while value is what consumers get in return for that price. The FCA believes that many firms already consider price throughout their day-to-day business decisions, but firms have not always considered the customer as being at the heart of this ‘value’ equation. The FCA ultimately believes that financial products and services should be priced in a way that reflects their value to consumers, and that consumers should be able to understand the costs and charges associated with these products and services. The regulator has, already on several occasions stepped in to regulate on price. This has occurred, for example, where the FCA felt that market dynamics and competition were not working for particular groups of customers. For instance, within the General Insurance market, existing customers often paid a higher renewal premium compared to new customers. Furthermore, within the High-Cost Short Term credit marketplace, the FCA viewed that historic pricing was ‘excessive’, not in the best interests of customers (many of whom were potentially vulnerable), and on occasion, argued that competition was not working for customers. Looking further back, many are often quick to point to the inherent issues with PPI as a product (for example, the limited ability to claim), but the excessive commission levels (often above the 50% tipping point outlined within Plevin) and the excessive erosion of value through an elongated distribution chain all combined to force the regulators hand to action and intervention. By looking at previous precedents, we can gain an understanding as to what the regulator wishes to avoid. So, what should firms be looking to evidence to demonstrate ‘good value’? PRICE AND VALUE: THE MOST DIFFICULT …

Vulnerability Registration Service (VRS) produced our Vulnerable Customer Exclusion report at the end of last year and it showed some frightening but not surprising statistics. We know from the FCA that around a quarter of the population consider themselves to be vulnerable and our report underlined that, but 10% of people deem themselves to be at risk of homelessness, eviction or repossession and 2% of people are having to turn to loan sharks. Our findings were collated before the cost-of-living crisis had hit. One of the most worrying things we’ve learnt while building VRS is how many of us are on the precipice – a risk of spiralling into unmanageable debt with no obvious route out, falling prey to unregulated lending, becoming so overwhelmed that we are unable to reach out or find the support that may be available. CCTA members already play a massive role in providing part of the safety net that sits between financial inclusion and enabling people to remain in control, rather than being caught up in a tidal wave of debt collection, enforcement, mental health impact, prepayment meters and seemingly no way out. I think many lenders are still bruised from adverse publicity five or more years ago. Headlines like ‘legal loan sharks’ and ‘toxic lending practices’ still resonate and understandably make us defensive. Are we exploiting vulnerable customers by lending to them? The reality is that vulnerable people come in many shapes and sizes and in many cases it is more than appropriate to lend to them. The alternative is to increasingly limit their options and remove that safety net. There is a big opportunity for lenders to grasp the nettle when it comes to managing vulnerable customers and, as obvious as it may sound, the key to do doing so is to accept that some of our customers are indeed vulnerable, to understand the challenges and then start to manage them. We are still a long way off from doing so and that is not sector specific. Virtually every organisation I speak to, in every sector, is grappling with (if indeed it’s high enough on their radar) how to tune their customer journey to extend the right support to their customer base. But nobody is going to come up with a magic solution – there is no master plan from government, regulators or stakeholders to address this. We need to just get on and do it because there will be regulator action, there will ultimately be fines and there will be increasing amounts of negative press and media focus. Most of all, it’s the right thing to do. We need to just get on and do it because there will be regulatory action, there will ultimately be fines and there will be increasing amounts of negative press and media focus. Most of all, it’s the right thing to do. The first step is to identify vulnerability. That is not limited to financial hardship or indebtedness – a tick in the box by doing …

Illegal money lending has a devastating, traumatic and long-lasting impact on victims, families and wider communities. This is driven by the predatory behaviour of loan sharks, which involves significant levels of harassment, intimidation and violence. Ruthless loan sharks exploit people in desperate need of quick cash. They charge extortionate rates of interest and trap their victims in a cycle of debt that can last for years and even decades. A report published by the Centre for Social Justice estimated 1.08 million people in England could be borrowing from an illegal money lender – more commonly known as a loan shark. This figure has more than trebled since 2010. Tens of thousands of people are ensnared by loan sharks each year and their debt can easily spiral out of control. These unscrupulous lenders befriend their victims and seek only to exploit people’s financial vulnerabilities. They often charge exorbitant interest rates and apply threats, fear or force to ensure repayment of loans. Almost two thirds (64%) of loan shark victims in England were introduced to the lender by friends or family, and over half (56%) had considered the loan shark a friend before borrowing from them. Predatory lenders can come in many different guises, which can make it difficult to identify them. The England Illegal Money Lending Team’s (IMLT) latest campaign, #LetsTalkLoanSharks, aims to raise awareness about these predatory practices and how you as a professional can help identify them. With price increases on everything from fuel to food making it increasingly tough for households to make ends meet, unlicensed lenders are stepping in, offering loans to the desperate at astronomical interest rates. Illegal money lending is on the rise, but it’s still a crime that remains largely underreported. By raising awareness in your community and encouraging clients to speak out, you can help fight this scourge and bring criminals to justice. Loan sharks are often seen as a last resort for people who have no other option for obtaining credit, including those with poor credit histories who are rejected by mainstream lenders. When you really need money but have a negative rating, an unexpected bill can be a critical moment that threatens to lead you down a dangerous path. The psychological impact of loan sharks is huge. These criminals are skilled at instilling fear into victims and their families, causing them to feel trapped, helpless and afraid. This often leads to the breakdown of relationships with family and friends, job loss and depression. The IMLT ran its national Stop Loan Sharks Week campaign from the 26 September to 2 October 2022 to highlight the help available to those who have been targeted by loan sharks, as well as increase awareness of this hidden crime in communities. This year’s campaign focused on reaching people who may not realise they are being exploited by loan sharks, as well as raising awareness of the support available to those who have already come into contact with an illegal lender. The #LetsTalkLoanSharks campaign aims to remove …

Following Boris Johnson’s somewhat forced resignation in July, a new leadership contest for the Conservative party took place over the summer. Due to the current political system and the ways in which leaders are elected, this inevitably meant a change of Prime Minster and a new Government. Liz Truss MP, winner of the leadership contest became Prime Minister shortly after. Truss, viewed as the favourite for most of the campaign, was elected as an MP in 2010 and has served as part of the Cabinet since 2014. Most recently holding the role of Foreign Secretary. Truss, recognised as being on the right of the Conservative Party, campaigned on a platform of the need to deliver economic growth and tax cuts. We have already started to see this action being taken as part of the mini budget at the end of September, with the planned rise in National Insurance being reversed, and a series of tax cuts. A change in policy direction has also been coupled with changes to other major roles in government. Very few remain from the Johnson administration. This has been seen at HM Treasury with the appointment of Kwasi Kwarteng as Chancellor and a new ministerial team. The structure of the team has also been amended. Previously it was the Economic Secretary that held responsibility for financial services regulation, the FCA and access to affordable credit. These have now become the responsibility of the Financial Secretary. Andrew Griffith MP was appointed to this position on the 8th of September. Griffith is a relatively new MP, elected in 2019. Prior to this he worked in private business for most of his career but not much is known yet about his stance on consumer credit. We have written to the new Minster to introduce the CCTA and the issues currently facing the alternative lending market. Aside from this we continue to have regular meetings with policy officials at HM Treasury as these remain in post despite changes in government. Other government departments have also seen changes. At the time of writing, we are waiting for some responsibilities to filter through on issues we are concerned about such as small businesses and financial inclusion. These should become clear in the coming weeks. Access to credit remains central to our messaging, particularly the role for commercial credit within the market. In recent times we have tried to draw political attention to the sharp reduction in the supply of regulated credit for consumers who are unable to access the ‘prime’ credit market. A report from the Centre for Social Justice (CSJ) in March found that over 1.1 million people are now having to use illegal lenders in England (up from the previous estimate of 300K). We believe there are now more people using loan sharks than regulated high-cost credit, something the Government should be concerned about. In the last three years the FCA has presided over the departure of more than 100 non-bank lenders serving these consumers; and in the same period …

It’s those two words again, isn’t it? Consumer Duty. Such innocuous sounding words, and ones that should feel like the natural thing to do for so many organisations and companies out there. But what do those words actually mean, and, crucially, how are they being interpreted? The premise is simple enough. There are three key elements; the Consumer Principle; Specific Behaviours; and Outcomes. The Consumer Principle aims to improve overall standards of behaviour; Specific Behaviours means that firms need to show they take all reasonable steps to avoid foreseeable harm to customers; and Outcomes means that firms need to ensure their customers receive fair value and fair products, that they understand how to use their products or services and receive support. So far, so straightforward. The worlds of financial services and customer service have made significant strides since the days of ‘the customer is always wrong’. So what’s the challenge? Firms need to consider how best they might demonstrate all of the new requirements, against a background of increasing economic turmoil and distress. Inflation is high. Food, petrol and energy bills are seeing price rises at rates that feel unprecedented to the younger generation. Over 4.5 million households are already struggling, demand for credit is rising, as is the level of support needed. Regulators will be looking closely at the world of consumer credit, and industry application of Consumer Duty. HOW DOES REGISTRY TRUST FIT IN? Registry Trust are neither a regulator, nor a regulated firm. So why should we care about Consumer Duty? Registry Trust run the Register of Judgments, Orders and Fines, which from an organisation’s point of view means that any kind of financial dispute you have with a consumer may well end up being represented on our public Register. We hold records on all county court judgments (CCJs), (decrees in Scotland) stretching back over the last five or six years, depending on the type of record. Registry Trust occupies an impartial place in the world of consumer credit and CCJs. We don’t pass judgment on the merits of any CCJ, we simply make sure it is recorded accurately. The link with Consumer Duty obligations and requirements is in our three main campaigns on Get Satisfaction, Partial Settlements and Claimant Data. Get Satisfaction calls for regulated firms to have the recording of satisfied or fully paid judgments sent through to the courts (and then to Registry Trust) in the same way that firms take out the original judgment. The mechanism for doing so already exists, and does not require structural change for firms, or legislative change for government. What it would do is give firms a way to demonstrate that they were acting in the interests of customers by ensuring they had their records updated when a debt was fully repaid or satisfied. Partial Settlements are not reflected in borrowing history or credit ratings. If a consumer and a firm come to a financial agreement, the consumer receives no public acknowledgement of the agreement, and therefore limited …

Earlier in the magazine we asked Lex Jones of the Registry Trust to talk a little more about the importance of the work that they do on county court judgments (CCJs). The CCTA is a strong supporter of their Get Satisfaction campaign to ensure that the judgments are kept up to date. When CCJs are satisfied it is important that there is a record. This should be win win for both the customer and lenders. The guidance around the Consumer Duty makes clear that a lender is looking to deliver the best outcome for a customer when they make sure information is passed along about a CCJ. Looking into the future, the sign that a customer has corrected their position, that they have taken steps to put things right is surely an indication that they may be a suitable customer in the future. From a behavioural perspective, in terms of credit risk, a lender might view favourably someone that has not just let time run down on their CCJ. However, this is only relevant if the regulator doesn’t close lending to those with CCJs. This was one of the issues that emerged from industry discussion earlier in the year. It became a concern that the FCA were questioning if it was right to lend to people that had CCJs. While this was an issue that emerged from informal conversation amongst members, we said at the time that we would pursue this further with the FCA. For us, the concern was that this looked like a misunderstanding of the nature of the market that many high-cost lenders serve. Our view has always been that, especially in sub-prime, customers may well have had a CCJ. In a statement that we were told we could share with the membership we were assured that the FCA’s position is not that you cannot lend to a customer with a CCJ. They said to us, “A firm should have regard to any information of which it is aware of at the time the creditworthiness assessment is carried out that may indicate that the customer is in, has recently experienced, or is likely to experience, financial difficulties. The fact that a customer has a CCJ is likely to be relevant to this assessment.” Hopefully that provides some assurance that there is no outright ban. They went on, “The extent and scope of the creditworthiness assessment, and the steps that the firm must take to satisfy the requirement that the assessment is a reasonable one, based on sufficient information, are dependent upon, and proportionate to, the individual circumstances of each case. The presence of a CCJ may be a factor suggesting that a more rigorous affordability assessment is necessary.” Now the quicker amongst you may realise that this is also not an endorsement of this lending. There is enough in that explanation, with a mention of proportionality, that supervisors could use to close this down while not imposing a full stop. There is also a deeper question as …

The FCA’s new Consumer Duty is a vital aspect of the current regulatory regime. This is a significant regulatory intervention aimed at raising standards. The proposed new principle – ‘A firm must act to deliver good outcomes for retail customers’ and the associated cross-cutting rules represent a clear shift in approach and a significant raising of the bar across the product lifecycle. Where good conduct was once demonstrated primarily through adherence to policies, processes, and rules, the FCA is itself focussing more on outcomes and expects firms to do the same. Rules-based compliance, in isolation, has given way to an outcomes-based approach with the FCA expecting firms, and their boards and senior executives to assess and monitor the outcomes customers receive. A way for firms to evidence against this requirement is to undertake customer-focused outcomes testing. WHAT IS OUTCOMES TESTING? Apart from ‘outcomes’ being the new buzzword (it is used 152 times in the FCA’s final guidance), outcomes testing is still quite a nebulous concept. So what is it? At Square 4, we view outcomes testing as a holistic review of a customer’s journey, to determine whether, based on their individual circumstances, customers received a good outcome. Typically we’ve found a level of direct customer engagement to be most effective. The articulation of the desired outcome should be defined by the firm for each component part of the customer journey, taking into consideration FCA requirements, its defined standards in relation to customer interactions aligned to its customer experience agenda, and its defined risk appetite. It is useful in the design of the outcomes testing methodology to consider regulatory expectations regarding the conduct of business and treatment of customers. However, it is imperative that outcomes testing is more than just a detailed assessment against the FCA rulebook. Upon reaching a consensus on a defined standard, firms should consider the KPIs and tolerances that are acceptable and how they are then going to measure the outcomes. Measuring outcomes can take many forms and would include intelligence around; product usage, customer contact, file reviews, MI from distributors and third-party suppliers, feedback from analytics on digital journeys, complaints, business persistency rates etc. Of these, customer contact is critically important, particularly to test the quality of financial promotions, disclosures, and customer understanding. In designing the Outcomes Testing Framework and methodology, we’d encourage firms to think about some of the key drivers behind the Consumer Duty, namely; the irrational nature of consumers, the behavioural biases they display, whether their products are fit for purpose and provide fair value, the level of financial literacy of their target market, and the imbalance of knowledge that exists between firms and consumers. The Consumer Duty requires firms to put consumers at the heart of their business and focus on delivering good outcomes. To do this effectively, firms need to consistently consider the needs of their customers, and how they behave, at every stage of the product/service lifecycle. With ongoing testing in place, this allows firms to continuously learn from their …

In the last edition of our magazine, I spoke about some exciting plans to further develop our services as a trade association. This edition presents a good opportunity for me to update our members, both long-standing and those that have joined us recently, on those plans. In short, it has been a busy period for the CCTA team but our plans have progressed well. Last time, I spoke about CCTA introducing more workshops and guidance papers on key regulatory topics. As many of you will know, we delivered the first of those workshops in August, covering the Consumer Duty and the key considerations for our members. It was a hugely successful workshop, attended by over 100 members and we received a lot of positive feedback. Following the workshop, we published our Consumer Duty Guidance Paper, which supported and guided our members in not only understanding the Duty but the key implementation and operational considerations. We continued with in-depth discussions around the requirements and expectations of the Duty at our recent Autumn Summit. But our work on Consumer Duty does not stop there. We know it remains a key regulatory topic, not just during the implementation phase, but for years to come. We are now working on delivering the next set of workshops and guidance papers. Before the end of the year, and going into early 2023, we will be covering key topics such as illegal money lending, online and social media financial promotions, commission disclosures, complaint handling and MI in light of the Consumer Duty and Statutory Debt Repayment Plan (SDRP) scheme, to name a few. In fact, members will have seen the recent release of our second guidance paper on the FCA’s improvements to the Appointed Representative (AR) regime. This is a must-read for our members who have, or plan to have, appointed representatives. Similarly, we previously spoke about a review of all our core regulated and non-regulated agreements and statutory documents, which a lot of members use. Considering the Consumer Duty, we have improved readability, layout, and accessibility. Key financial information, as well as terms and conditions are clearer and aid consumer understanding. We are now at the latter stages of final review and approval, and aim to release the new versions towards the end of the year. Concurrently, we are starting discussions with some potential online training platform and software providers. We previously mentioned our intentions to introduce training and CPD for our members. Although our discussions are at very early stages, we intend to launch compliance training as soon as practicable for member firms and their staff. Our plans are to make available training modules that will cover many of the key legal and regulatory topics in our sector. These include (but not limited to) complaints, financial promotions, CONC, the Consumer Credit Act, treating customers fairly, vulnerable customers, anti-money laundering, anti-bribery, the Consumer Duty, whistleblowing, data protection/GDPR and SM&CR. As we approach the end of 2022, here at CCTA we are already planning what 2023 will …