The City provides a powerful stage, steeped in tradition and grand spectacle, but it can feel a long way from the families and communities that our members serve every day.

CCTA members provide real-world credit that makes everyday life work.

They help someone buy the not-so-new car that gets them to work. Replace the broken freezer. Keep the washing machine running when the family can’t do without it. Finance the phone that’s a lifeline for work and staying in touch. Fund home improvements when moving simply isn’t an option. This is practical, purposeful lending – and it matters.

When we hear about a new process for raising concerns about FOS decisions, we welcome the intent. But we ask: Will it work for smaller firms? Will it be accessible, transparent, and proportionate?

There has been a considerable focus on innovation and new products within the industry, which is welcome. But we also need to get the basics right.

We would like to see:

1. Better alignment between the FCA and FOS
   The gap between the FCA’s regulatory objectives and the FOS’s “fair and reasonable” test creates uncertainty. We need closer alignment to provide confidence for firms and consumers.
2. Greater oversight of FOS decisions
   Precedent-setting complaints need a more transparent, fairer review process. Judicial review is expensive, slow, and often doesn’t address the right questions. The FOS could be well within their powers, passing the JR test, but still get it wrong.
3. Stronger scrutiny of professional representatives
   The rise in templated, low-quality complaints from claims firms and legal representatives undermines trust and swamps firms. The system needs better quality control.
4. Improved handling of mass complaints
   We should work together to identify patterns early, consult openly, and address issues thematically – not firm by firm. I think we should get to the problems quickly.
5. Certainty and proportionality for smaller firms
   The current process can be vague, resource-heavy, and inconsistent. Smaller firms need clear timelines, reasonable expectations, and proportionate oversight.

For each of these headlines, we have more to say and more details to provide. As a trade association, we want to debate and discuss

Reform must do more than tweak the system – it must be genuine reform, so that UK families can access the credit they need.