Finding the balance: FOS redress reform that is fair, predictable, and sustainable

Published 23 September 2025

Reform of the financial redress system is long overdue. It is something that the CCTA has campaigned for over the years. We are pleased to see progress and plans for further changes. However, if change is to last, it must be sustainable for all types of firms. One that also balances the interests of consumers and firms. For the industry, this means designing rules that not only suit the very largest, but also reflect the pressures faced by smaller lenders.

More than a lick of paint: Introducing the new CCTA website

Published 02 August 2025

Since 2016, our website has helped members find answers, register for events, and stay informed. But we knew we could do better. So we have rebuilt it, from the ground up, to give you improved access, better navigation, and personalised tools that make your membership work harder for you. We recognise that the website is a crucial part of the membership journey for both existing and future members. The new site has several notable additions and improvements. I wanted to outline our plans, while also illustrating how you can get the most out of the new ccta.co.uk.

Changes ahead? CCTA review key regulatory developments

Published 01 August 2025

From a regulatory perspective, it is set to be another big year within the world of alternative credit. At our Summit, I talked about the key changes we were expecting in 2025. Here, I update on progress and provide details of new regulatory developments that will affect members.

Bridging the gap: Building confidence and compliance with CCTA Academy

Published 01 August 2025

Look at any Financial Conduct Authority (FCA) review in consumer credit and one message stands out: learning and development are critical. They not only ensure staff have the technical skills needed to deliver good outcomes but also help shape a firm’s culture.

How does the PSD request sit with the FCA’s new five-year strategy?

Published 28 May 2025

Vigilance Conference: CCTA publish event write-up

Published 23 May 2025

At the end of March we held our Vigilance Conference in central London. Delegates attended from across the CCTA membership including lenders of various sizes, brokers and associates. Addleshaw Goddard kindly hosted the event at their London offices.

Supporting vulnerable customers: FCA review highlights

Published 22 May 2025

On 7 March, the FCA published their findings into a review of firms’ treatment of customers in vulnerable circumstances, including their consumer research and examples of good and poor practices. It is clear that vulnerable customers remain a top priority for the regulator, and rightly so. They should be a priority for firms too.

Cultivating relationships: Introducing your new Membership Manager

Published 22 May 2025

I’m delighted to introduce myself as the new Membership Manager at the Consumer Credit Trade Association (CCTA). It’s an exciting time to join the organisation, and I’m eager to connect with all of you – our valued members – to ensure that you receive the best possible support, insights, and services that CCTA has to offer.

Ensuring our voices are heard: Jason Wassell on credit information reform

Published 21 May 2025

Over the past year, I’ve represented the Consumer Credit Trade Association on the Industry Working Group (IWG) tasked with developing proposals for a new Credit Reporting Governance Body (CRGB). It is an important and potentially far-reaching piece of work that could change the way credit data is overseen in the UK—and it’s vital that smaller and specialist lenders are not just consulted but properly considered in how the new regime is shaped.

The FCA’s new five-year strategy and what it might mean for alternative credit

Published 01 May 2025

Earlier in the spring, the FCA launched its new five-year strategy that will run until 2030. The aim is to deepen trust, rebalance risk, support growth and improve lives. The regulator has outlined four main themes for its future areas of work as part of the strategy which can be seen below: Be a smarter regulator – predictable, purposeful and proportionate. The FCA will improve its processes and embrace technology to become more efficient and effective. Support sustained economic growth – by enabling investment, innovation and ensuring the continued competitiveness of the UK’s world-leading financial services. Help consumers – to navigate their financial lives by working with the wider industry to boost trust, product innovation and ensure the right information and support is available for people to take informed financial decisions. Fight financial crime – by focusing on those who seek to do harm. The strategy will go further to disrupt criminals and support firms to be an effective line of defence. We have reviewed the strategy and welcome much of the shift in tone. There is the promise of a move away from over-cautious regulation towards a more proportionate, risk-balanced approach. The FCA acknowledges that regulatory standards – while essential – can also unintentionally stifle innovation and create barriers for new entrants. The new strategy promises a more flexible process and smarter use of data. Despite this rhetoric of risk rebalancing and smarter regulation, just now the burden of compliance remains heavy – especially for smaller firms. This is an area where we would like to see change. Elsewhere, the strategy makes clear that the Consumer Duty isn’t going anywhere. If anything, it will become more deeply embedded in how the FCA assesses conduct. Alternative lenders will need to continue evidencing that their products offer fair value, that communications support consumer understanding, and that they’re identifying and supporting vulnerable customers appropriately. Of course we have questions that we will pick up with the FCA in future meetings. Some of this may be a cultural challenge for the FCA. For example, many decisions and interpretations rest with various FCA teams, especially in the world of principles and outcomes. How do you ensure that this change reaches the frontline discussions between firms and the FCA? How will the FCA incorporate access to financial services as a measurable outcome of the strategy, particularly for underserved markets? We must not lose focus of the need to improve access to credit. What metrics will the FCA use to assess whether competition and investment have improved across different segments of financial services? We can focus on the big numbers, but we know that small markets help underserved groups. How do we track success or failure in these different segments? At the CCTA, we will continue to be a strong voice for smaller lenders – advocating for proportionate, practical regulation that allows responsible firms to thrive and serve consumers well. We will all need to work together to ensure the regulator delivers on the aims of its new strategy.  

HM Treasury publishes action plan on regulation – aims to support growth

Published 18 March 2025

Yesterday, the Chancellor met top regulator bosses in Downing Street to discuss an action plan on regulation. The review aims to cut the administrative cost of regulation, make Britain the best place to do business and drive economic growth. We applaud the ambition and the speed at which the Government has been moving. Action plan on regulation The plan aims to overhaul the regulatory system so that it: supports growth. Provide a regulatory system that not only protects consumers and supports competition, but also encourages new investment, innovation, and growth. is targeted and proportionate. The government should regulate only where necessary and allow space for discretion and good behaviour. is transparent and predictable. To foster the certainty essential for investment, it is vital that the regulatory regime is stable, predictable and consistent. adapts to keep pace with innovation. Our approach to regulation must allow the UK to take advantage of new technologies and innovations. We welcome these aims. Recently, we wrote about the importance of the smaller non-bank lenders we represent. A big part of their challenge is regulatory. We have long discussed the need to reduce the regulatory burden on firms, but we are increasingly also discussing the importance of certainty. Yes, as the Government has identified, compliance costs have increased considerably over recent years. We have long said that regulators’ cost-benefit work can be disappointing. It can lack an understanding of actual costs and seem to be built with banks in mind. Late last year, we wrote in the media about new proposals from the Financial Conduct Authority to ask lenders to provide detailed information about every transaction they carry out. This follows a vast amount of work to implement the Consumer Duty. The burden is real and pressing. Certainty is just as important as the burden. However, certainty is equally vital. It is key to have confidence that you understand the regulator’s expectations. It allows you to grow and develop without second-guessing everything you do. Let’s be very clear. This is not about deregulation. In many areas, certainty is about providing more direction, not less. It has essential knock-on impacts. Certainty gives firms confidence that they are compliant, but it is also vital in attracting the investment they need for growth. Certainty also ensures access to credit for individuals who struggle to borrow elsewhere, as firms can continue to offer services to these consumers rather than stepping back out of fear. The action plan also includes some specific measures for financial services. The Treasury will also explore ways to streamline financial services regulators’ ‘have regards’ to improve predictability and business confidence. Regulators will now also be subject to performance reviews twice a year. They will be judged against a set of targets agreed with the businesses they affect, such as how quickly they decide on planning applications and new licenses for companies and products. It would be good to see the FCA supporting new entrants into the alternative credit sector. Examining the role of the Financial Ombudsman …

Call for Input on mass redress – an opportunity for change

Published 06 February 2025

Last week we submitted our response to the Call for Input on modernising the redress system. We took this as an opportunity to raise a couple of wider key topics that we were keen to include around the complaints process. One of these is dialogue with the industry around complaints, to improve outcomes for all concerned – firms, the Ombudsman, and ultimately, the consumer. While we believe there are some tangible changes that can be made to the process (which we raise within our submission) there is a need for a more significant change within the FOS, and how it interacts with the industry and other stakeholders. We believe that the FOS can significantly improve the current framework for managing matters with wider implications by developing a new culture, fostering greater transparency, collaboration, and efficiency. The Wider Implications Framework’s (WIF) role could be enhanced to better manage systemic issues and prevent escalation. Early identification of risks through the WIF would also reduce the likelihood of costly mass redress events and encourage proactive handling of systemic issues to deliver consistent and timely redress for consumers. So, we are calling for regular feedback loops and consultation mechanisms to be established to identify emerging trends collaboratively. This could include real-time communication channels and the establishment of stakeholder forums. Through this firms, consumer representatives and trade bodies could directly engage with the regulators. This would strengthen relationships between regulators, industry, and consumer groups. It would provide valuable insights to inform regulatory actions. There is an opportunity to enhance transparency, involving those outside the regulatory family also. Another area we have identified is the issue of time limits and the ambiguity that surrounds them. We strongly believe the FCA and FOS should review the current time limits for referring complaints to provide greater certainty for firms while maintaining fair consumer protections. The current rules—particularly the “three-year from the date of knowledge” provision introduce significant ambiguity, leaving firms vulnerable to open-ended liability and increasing the risk of inconsistent outcomes. To address this, we propose a few changes. We recommend introducing an absolute longstop from the event date, giving rise to the complaint. This would provide firms with a clear liability endpoint, while ensuring consumers have ample time to bring complaints. The “date you knew” rule should also be clarified. The three-year rule is subjective and inconsistently applied. We have seen the FOS place an unreasonable burden on firms to prove when consumers become aware of their right to complain. There should be a clear burden of proof that balances fairness between firms and consumers, ensuring firms are not unfairly burdened. We believe that this will help market integrity and competitiveness. In creating a predictable regulatory environment, it would encourage investment and innovation that has been so hard to achieve in alternative lending given their recent experience of the complaints system. These are two examples of areas that could be improved both to better handle mass redress events but also the wider complaints framework so it functions …