Anyone in consumer credit will likely know about the FCA’s recent consultation on Product Sales Data (PSD) reporting.

The FCA has stated that the proposals aim to collect further data from the market to inform their supervisory and policy approach.

The proposals would mean data would be provided to the FCA on every loan issued across credit cards, motor finance, etc. That includes information about every customer.

The FCA themselves say that 120 million credit agreements currently cover around 40 million individuals. They are also requesting “back book” data on every agreement that is currently live. This is a massive amount of data for the regulator to hold.

We have concerns across a range of areas

The CCTA has concerns not only about the regulatory burden that reporting on this scale will place on firms (with smaller firms likely to be disproportionally affected) but also if it is right or safe for a financial regulator to hold this level of data.

This clashes with the ideas that are developing in financial services around data protection. We continue to talk about data minimisation, seeking out and keeping only the personal information required.

If these plans go ahead, the level of data the financial regulator will hold about the UK public and their intimate financial details will be a step change.

As part of our advocacy work on the issue, we have been raising these concerns with various stakeholders since the publication of the consultation and directly with the regulator.

That work has included journalists who cover financial services and regulation. We briefed the Sunday Times about the proposals and what they would mean for consumers. Along with our briefings, we supplied comments about the impact the data reporting would have on alternative lending.

This week, we saw a piece published in the Sunday Times, which can be read here. (behind paywall). It picks up on the main CCTA concerns about the proposals and the additional burden likely to fall on small firms. The association is also quoted.

The piece was also picked up the CityAM, providing some extra coverage of our arguments.

More to be done

The official consultation has now closed. However, as part of our continuing work on the issue, we ask members to review the more detailed proposals. Please share concerns in terms of what is workable. We will be looking to raise these directly with the FCA in the coming weeks.