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.

Increasing regulatory burden leads to a drop in regulated supply

Published 13 April 2023

We are currently reviewing the FCA Strategy to determine its implications for our members. That is being considered alongside the FCA’s proposed regulatory fees and levies. Too often regulators set rules that work well for the big banks and mega insurance companies. The FCA often fails to recognise the important part played by smaller firms and that increasing regulatory burden needs to be considered.

‘The Future of Credit’ research – comments by CCTA CEO

Published 22 February 2023

Nice to be invited to the Finance and Leasing Associations dinner tomorrow, always a remarkable event. More important than the invitation to dinner is the strong collaboration between credit associations on issues that are of importance to our members. One of the common areas of work is the promotion of the value of credit to UK families and businesses. So, I was pleased to see the work being carried out by the FLA on the use of credit and especially the future of credit.

Changing track: What the new government means for the industry

Published 24 October 2022

Following Boris Johnson’s somewhat forced resignation in July, a new leadership contest for the Conservative Party took place over the summer. This meant a change of Prime Minister and a new Government.

Appointed Representatives

Published 05 October 2022

The Appointed Respresentatives (AR) regime is a longstanding feature of UK financial services regulation. Legislation for the AR regime was first established in 1986 for investment services activity but was later adapted and applied to a wider range of financial services under the Financial Services and Markets Act (FSMA 2000). It allows agents and representative firms to engage in regulated activities without the need for being directly authorised by the FCA. The ‘Principal’ (the regulated firm or person who allows the AR to operate under their permissions) effectively takes responsibility for the AR’s conduct and oversight.

CCTA response to BNPL Consultation

Published 19 January 2022

HM Treasury’s consultation on Buy-Now Pay-Later (BNPL) products has recently closed. Here we share the main points from our response. These are key principles we believe HM Treasury needs to consider when shaping the future regulation of consumer credit.

CCTA comment on HM Treasury consultation on BNPL regulation

Published 21 October 2021

CCTA commenting on HM Treasury consultation on the regulation of BNPL said: “The consultation on BNPL is welcome, but it highlights that the current regulation of consumer credit is complex and unwieldy. These products should already be regulated by the FCA, but the system takes too long to change.”

CCTA respond to future regulatory framework of financial services report

Published 06 July 2021

The Treasury Select Committee has today published its report on the Future Regulatory Framework of Financial Services. It is good to see that the committee has recommended that the Treasury consider how the decision-making processes of the Financial Ombudsman Service (FOS) would interact with the future regulatory framework for the FCA, something we called for in our written evidence to the committee. The HM Treasury consultation currently makes no mention of the FOS.