FCA engagement

Published 13 November 2024

The FCA’s oversight of regulated consumer credit firms is at an all-time high. The regulators ongoing scrutiny of regulated consumer credit firms stems their focus areas around conduct, Consumer Duty and vulnerable customers (to name a few). This event was suitable for Board-level Directors and Senior Managers.

FCA keeps a firm grip on the oversight of Appointed Representatives

Published 12 September 2024

Last week the FCA published the findings of its review of how principal firms are meeting its enhanced appointed representative rules, introduced in December 2022. As a reminder, an appointed representative (AR) is a firm that undertakes regulated activities and acts as an agent for a firm directly authorised by the FCA. This firm is known as the appointed representative’s “principal” firm.

Reducing the burden

Published 08 August 2024

The end of July saw the first anniversary of the implementation of the FCA’s Consumer Duty. This meant vast amounts of work undertaken by regulated firms to prepare, looking to embed the Duty in every stage of the customer journey.  We have supported CCTA members through this process, but it is no means finished, as we know this will be a continual process, especially as requirements for closed products and the Annual Board Report have now come into force too.

The general election and a possible change in government

Published 30 May 2024

On 22 May, Rishi Sunak surprised most of the UK by calling a General Election to take place on 4 July. Much of the political world thought it would take place in the autumn, but there was a growing sense that this was as good as it would get for the Conservatives. Though polls can be misleading and often narrow as election day approaches, Labour has consistently been around twenty points ahead of the Conservatives. It seems unlikely that the Tories will feature in the next government. Labour looks likely to be at the head of the next government in some form, possibly with a majority, a minority, or a coalition arrangement.

Treasury Committee looks at the issue of de-banking

Published 20 May 2024

Earlier this month the influential Treasury Select Committee published their report into SME Finance. The Committee contains MPs from across the House of Commons, representing all major parties. The report was commissioned to look at the recent experiences of small businesses. It was designed to consider the issue of access to finance and what else can be done to encourage business growth.

Technology – the pace of change is rapid

Published 07 May 2024

Developments in technology have been back in the news in recent weeks. Open Banking, the use of data and AI have all received mentions. Though they offer exciting possibilities, these new developments need to be balanced with the appropriate checks. We are all aware of the potential unintended consequences and the lag that can occur between innovation and necessary regulation.

Changes in home credit

Published 22 January 2024

Back in the early noughties, the home credit market was under intense scrutiny for a lack of competition which led to the then Competition Commission investigating the sector. It was thought that it was difficult for consumers to compare products or switch between providers to find the best price. Following the investigation an order was passed that placed various conditions on the sector.

A look ahead at 2024

Published 09 January 2024

2023 was a busy year for the consumer credit sector and the CCTA. It saw the introduction of the FCA’s Consumer Duty, new research into the impact of illegal lending and further engagement with our key stakeholders- the FCA, the FOS and HM Treasury on a range of issues. Here we explore some of the developments we expect in 2024.

Level playing field in consumer credit?

Published 03 December 2023

Unsurprisingly, consumer credit regulation plays an essential part in the lending market. A level playing field in consumer credit is a crucial principle. Firms of different sizes and formats and providing various products need access to the market. We can see some areas where we may come off track with the current discussions about regulating Buy Now Pay Later (BNPL) and Big Tech entering into financial services.

Engaging on the FCA’s Product Sales Data consultation

Published 24 November 2023

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.

Regulation of BNPL: An update

Published 06 November 2023

We think the FCA announcement on Buy Now Pay Later (BNPL) activity is interesting for several reasons. First, it is fascinating that over 1 in 4 adults had used BNPL in the second half of last year. This raises some critical questions about the regulation of BNPL. The FCA believes about 14 million people used BNPL in the second half of last year (2022). That is about 27% of the population over six months, compared with 17% in the preceding twelve months. If we want to mess around with the statistics, then that suggests that we are heading towards doubling earlier figures.

Technology paper

Published 01 November 2023

Artificial Intelligence, Machine Learning, and ChatGPT are words we hear more and more. There is a lot of new technology appearing on the scene which will revolutionise not only the financial services market but also the wider world in the next few years. Technology has always played an important part in the development of alternative lending products. For that reason, we wanted to share a paper that looks at some of these developments in a little more detail.