CCTA Chief Executive announced as Credit Week Leadership Awards finalist

Published 14 February 2023

I am very pleased to hear that I have been shortlisted for Business Leader of the Year in Alternative Finance award held during Credit Week. These are always interesting awards reflecting credit leadership across a range of sectors. Organised by Credit Strategy every year we watch our members do well across the sectors. Every year we post our congratulations to others in the days after. It was a pleasant surprise when asked if I was happy for my name to go forward and to be a finalist is just the cherry on top. It is all about the great team at the CCTA. Up against some great other leaders, we are so happy that we have received this recognition. This seems like a good opportunity to say how I work with a great team that keeps the CCTA moving. Our small team are specialists in their function areas – across policy, membership and communication. Campaigning hard for our members, providing our members with advice and building a network of lenders, brokers and associates. More than that, the team are willing and able to step in and help each other. Of course, the CCTA would be nothing without volunteers who serve on our Council, giving up their time to help direct the organisation. We are also helped by a small band of members who take part in our discussions. They are willing to share their experiences and insights. It is that knowledge and experience that allows us to bring focus to our work. Credit leadership We will continue to be strong advocates for alternative lenders; be a source of insight and facilitators of a network of lenders and associates. My congratulations to everyone else nominated for The Leadership Awards, taking place on 16 March 2023, as part of Credit Week.

FOS discussion update

Published 09 February 2023

It was good to talk to the Financial Ombudsman Service earlier in the week. We raised some concerns that our members had during the FOS discussion. However, we also welcomed their commitment to more engagement with the consumer credit industry. One of the issues that we are particularly keen to raise in our FOS discussion is their approach to Consumer Duty. The risk that people have mentioned to me is whether we will see differences in approach between the Financial Conduct Authority and the FOS. Unfortunately, there is a belief that sometimes there is a disjoint between the two organisations. I know that they would push back strongly on that suggestion. However, there have been a number of times when it seems that there are differences. From what we heard, the FOS are well aware of this concern and are trying to mitigate this risk by working closer to the FCA. There was an interesting FOS discussion about good outcomes. Looking at how this is implemented across different sectors and products. Remember if you are a CCTA member then please keep talking to us. Raise any issues you have with us. I am always happy to provide more information about our work. If you are not a member of the CCTA but are involved in non-bank lending, then please consider joining. More information can be found here.

Path to Success: an update on membership services

Published 24 October 2022

In the last edition of our magazine, I spoke about some exciting CCTA plans to further develop our services as a trade association. This edition presents a good opportunity for me to update our members. Both long-standing members and those who have joined us recently. In short, it has been a busy period for the CCTA team but our plans have progressed well. Last time, I spoke about CCTA introducing more workshops and guidance papers on key regulatory topics. Consumer Duty dominates our work As many of you will know, we delivered the first of those workshops in August. This covered the Consumer Duty and the key considerations for our members. It was a hugely successful workshop. It was attended by over 100 members and we received a lot of positive feedback. Following the workshop, we published our Consumer Duty Guidance Paper. This supported and guided our members in not only understanding the Duty but also the key implementation and operational considerations. We continued with in-depth discussions around the requirements and expectations of the Duty at our recent Autumn Summit. But our work on Consumer Duty does not stop there. We know it remains a key regulatory topic. Not just during the implementation phase, but for years to come. We are now working on delivering the next set of workshops and guidance papers. Before the end of the year, and going into early 2023, we will be covering key topics such as illegal money lending, online and social media financial promotions, commission disclosures, complaint handling and MI in light of the Consumer Duty and Statutory Debt Repayment Plan (SDRP) scheme, to name a few. In fact, members will have seen the recent release of our second guidance paper on the FCA’s improvements to the Appointed Representative (AR) regime. This is a must-read for our members who have or plan to have, appointed representatives. Similarly, we previously spoke about a review of all our core regulated and non-regulated agreements and statutory documents. A lot of members use these. Recognising the Consumer Duty, we have improved readability, layout, and accessibility. Key financial information, as well as terms and conditions, are clearer and aid consumer understanding. We are now at the latter stages of final review and approval and aim to release the new versions towards the end of the year. Plans for an online training platform for CCTA members We are starting discussions with some potential online training platforms and software providers. We previously mentioned our intentions to introduce training and CPD for our members. Although our discussions are at very early stages, we intend to launch compliance training as soon as practicable. Our plans are to make available training modules that will cover many of the key legal and regulatory topics in our sector. These include (but are not limited to) complaints, financial promotions, CONC, the Consumer Credit Act, treating customers fairly, vulnerable customers, anti-money laundering, anti-bribery, Consumer Duty, whistleblowing, data protection/GDPR and SM&CR. CCTA Planning for 2023 As we approach …

Up in the Air: When is it appropriate to lend to those with CCJs?

Published 24 October 2022

In the latest issue of CCTA Magazine, we asked Lex Jones of the Registry Trust to talk a little more about the importance of the work that they do on county court judgments (CCJs). The CCTA is a strong supporter of their Get Satisfaction campaign. It is vital to ensure judgments are kept up to date. When CCJs are satisfied it is important that there is a record. This should be a win-win for both the customer and lenders. Consumer Duty focuses on good outcomes. The Consumer Duty makes clear that a lender should deliver the best outcome for a customer. That includes making sure information is passed along about a CCJ. Looking into the future, surely this is a useful indication. Especially if the customer has corrected their position. Especially if they have taken steps to put things right. Surely this is an indication that they may be a suitable customer in the future. From a behavioural perspective, in terms of credit risk, a lender might view favourably someone who has not just let time run down on their CCJ. Should CCJs prevent future lending? However, this is only relevant if the regulator doesn’t close lending to those with CCJs. This was one of the issues that emerged from industry discussions held with CCTA members earlier in the year. It became a concern that the FCA seemed to be questioning whether it was right to lend to people who had CCJs. This was an issue that emerged from an informal conversation among members. We said at the time that we would pursue this further with the FCA. For us, the concern was that this looked like a misunderstanding of the nature of the market that many high-cost lenders serve. We believe that, especially in subprime, customers may well have had a CCJ. FCA provides clarification. In a statement that we were told we could share with the membership, we were assured that the FCA’s position is not that you cannot lend to a customer with a CCJ. They said to us, “A firm should have regard to any information of which it is aware of at the time the creditworthiness assessment is carried out that may indicate that the customer is in, has recently experienced, or is likely to experience, financial difficulties. The fact that a customer has a CCJ is likely to be relevant to this assessment.” Hopefully, that provides some assurance that there is no outright ban. They went on, “The extent and scope of the creditworthiness assessment, and the steps that the firm must take to satisfy the requirement that the assessment is a reasonable one, based on sufficient information, are dependent upon, and proportionate to, the individual circumstances of each case. The presence of a CCJ may be a factor suggesting that a more rigorous affordability assessment is necessary.” The quicker amongst you may realise that this is also not an endorsement of this lending. There is enough in that explanation, with a mention of …

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. Truss emerges as Prime Minister. Liz Truss MP, winner of the leadership contest became Prime Minister shortly after. Truss, viewed as the favourite for most of the campaign, was elected as an MP in 2010 and has served as part of the Cabinet since 2014. Most recently holding the post of Foreign Secretary. Truss, recognised as being on the right of the Conservative Party, campaigned on a platform of the need to deliver economic growth and tax cuts. We have already started to see this action being taken as part of the mini-budget at the end of September, with the planned rise in National Insurance being reversed, and a series of tax cuts. A change in policy direction has also been coupled with changes to other major roles in government. Very few remain from the Johnson administration. This has been seen at HM Treasury with the appointment of Kwasi Kwarteng as Chancellor and a new ministerial team. The Treasury makes changes. The structure of the team has also been amended. Previously it was the Economic Secretary that held responsibility for financial services regulation, the FCA and access to affordable credit. These have now become the responsibility of the Financial Secretary. Andrew Griffith MP was appointed to this position on the 8th of September. Griffith is a relatively new MP, elected in 2019. Prior to this, he worked in private business for most of his career but not much is known yet about his stance on consumer credit. We have written to the new Minster to introduce the CCTA and the issues currently facing the alternative lending market. Aside from this, we continue to have regular meetings with policy officials at HM Treasury as these remain in post despite changes in government. Other government departments have also seen changes. At the time of writing, we are waiting for some responsibilities to filter through on issues we are concerned about such as small businesses and financial inclusion. These should become clear in the coming weeks. Access to Credit as over 1 million use illegal lenders Access to credit remains central to our messaging, particularly the role of commercial credit within the market. In recent times we have tried to draw political attention to the sharp reduction in the supply of regulated credit for consumers who are unable to access the ‘prime’ credit market. A report from the Centre for Social Justice (CSJ) in March found that over 1.1 million people are now having to use illegal lenders in England (up from the previous estimate of 300K). We believe there are now more people using loan sharks than regulated high-cost credit, something the Government should be concerned about. The FCA has played a part in the demise of regulated credit In the last three years, the FCA has presided over the …

Breaking the silence
It’s time to talk about illegal lending

Published 10 October 2022

Illegal money lending has a devastating, traumatic and long-lasting impact on victims, families and wider communities. This is driven by the predatory behaviour of loan sharks, which involves significant levels of harassment, intimidation and violence. Ruthless loan sharks exploit people in desperate need of quick cash. They charge extortionate rates of interest and trap their victims in a cycle of debt that can last for years and even decades. A report published by the Centre for Social Justice estimated 1.08 million people in England could be borrowing from an illegal money lender – more commonly known as a loan shark. This figure has more than trebled since 2010. Tens of thousands of people are ensnared by loan sharks each year and their debt can easily spiral out of control. These unscrupulous lenders befriend their victims and seek only to exploit people’s financial vulnerabilities. They often charge exorbitant interest rates and apply threats, fear or force to ensure repayment of loans. Almost two thirds (64%) of loan shark victims in England were introduced to the lender by friends or family, and over half (56%) had considered the loan shark a friend before borrowing from them. Predatory lenders can come in many different guises, which can make it difficult to identify them. The England Illegal Money Lending Team’s (IMLT) latest campaign, #LetsTalkLoanSharks, aims to raise awareness about these predatory practices and how you as a professional can help identify them. With price increases on everything from fuel to food making it increasingly tough for households to make ends meet, unlicensed lenders are stepping in, offering loans to the desperate at astronomical interest rates. Illegal money lending is on the rise, but it’s still a crime that remains largely underreported. By raising awareness in your community and encouraging clients to speak out, you can help fight this scourge and bring criminals to justice. Loan sharks are often seen as a last resort for people who have no other option for obtaining credit, including those with poor credit histories who are rejected by mainstream lenders. When you really need money but have a negative rating, an unexpected bill can be a critical moment that threatens to lead you down a dangerous path. The psychological impact of loan sharks is huge. These criminals are skilled at instilling fear into victims and their families, causing them to feel trapped, helpless and afraid. This often leads to the breakdown of relationships with family and friends, job loss and depression. The IMLT ran its national Stop Loan Sharks Week campaign from the 26 September to 2 October 2022 to highlight the help available to those who have been targeted by loan sharks, as well as increase awareness of this hidden crime in communities. This year’s campaign focused on reaching people who may not realise they are being exploited by loan sharks, as well as raising awareness of the support available to those who have already come into contact with an illegal lender. The #LetsTalkLoanSharks campaign aims to remove …

Changing track
What the new government means for the industry

Published 10 October 2022

Following Boris Johnson’s somewhat forced resignation in July, a new leadership contest for the Conservative party took place over the summer. Due to the current political system and the ways in which leaders are elected, this inevitably meant a change of Prime Minster and a new Government. Liz Truss MP, winner of the leadership contest became Prime Minister shortly after. Truss, viewed as the favourite for most of the campaign, was elected as an MP in 2010 and has served as part of the Cabinet since 2014. Most recently holding the role of Foreign Secretary. Truss, recognised as being on the right of the Conservative Party, campaigned on a platform of the need to deliver economic growth and tax cuts. We have already started to see this action being taken as part of the mini budget at the end of September, with the planned rise in National Insurance being reversed, and a series of tax cuts. A change in policy direction has also been coupled with changes to other major roles in government. Very few remain from the Johnson administration. This has been seen at HM Treasury with the appointment of Kwasi Kwarteng as Chancellor and a new ministerial team. The structure of the team has also been amended. Previously it was the Economic Secretary that held responsibility for financial services regulation, the FCA and access to affordable credit. These have now become the responsibility of the Financial Secretary. Andrew Griffith MP was appointed to this position on the 8th of September. Griffith is a relatively new MP, elected in 2019. Prior to this he worked in private business for most of his career but not much is known yet about his stance on consumer credit. We have written to the new Minster to introduce the CCTA and the issues currently facing the alternative lending market. Aside from this we continue to have regular meetings with policy officials at HM Treasury as these remain in post despite changes in government. Other government departments have also seen changes. At the time of writing, we are waiting for some responsibilities to filter through on issues we are concerned about such as small businesses and financial inclusion. These should become clear in the coming weeks. Access to credit remains central to our messaging, particularly the role for commercial credit within the market. In recent times we have tried to draw political attention to the sharp reduction in the supply of regulated credit for consumers who are unable to access the ‘prime’ credit market. A report from the Centre for Social Justice (CSJ) in March found that over 1.1 million people are now having to use illegal lenders in England (up from the previous estimate of 300K). We believe there are now more people using loan sharks than regulated high-cost credit, something the Government should be concerned about. In the last three years the FCA has presided over the departure of more than 100 non-bank lenders serving these consumers; and in the same period …

The full picture
Increasing visibility of useful customer data

Published 10 October 2022

It’s those two words again, isn’t it? Consumer Duty. Such innocuous sounding words, and ones that should feel like the natural thing to do for so many organisations and companies out there. But what do those words actually mean, and, crucially, how are they being interpreted? The premise is simple enough. There are three key elements; the Consumer Principle; Specific Behaviours; and Outcomes. The Consumer Principle aims to improve overall standards of behaviour; Specific Behaviours means that firms need to show they take all reasonable steps to avoid foreseeable harm to customers; and Outcomes means that firms need to ensure their customers receive fair value and fair products, that they understand how to use their products or services and receive support. So far, so straightforward. The worlds of financial services and customer service have made significant strides since the days of ‘the customer is always wrong’. So what’s the challenge? Firms need to consider how best they might demonstrate all of the new requirements, against a background of increasing economic turmoil and distress. Inflation is high. Food, petrol and energy bills are seeing price rises at rates that feel unprecedented to the younger generation. Over 4.5 million households are already struggling, demand for credit is rising, as is the level of support needed. Regulators will be looking closely at the world of consumer credit, and industry application of Consumer Duty. HOW DOES REGISTRY TRUST FIT IN? Registry Trust are neither a regulator, nor a regulated firm. So why should we care about Consumer Duty? Registry Trust run the Register of Judgments, Orders and Fines, which from an organisation’s point of view means that any kind of financial dispute you have with a consumer may well end up being represented on our public Register. We hold records on all county court judgments (CCJs), (decrees in Scotland) stretching back over the last five or six years, depending on the type of record. Registry Trust occupies an impartial place in the world of consumer credit and CCJs. We don’t pass judgment on the merits of any CCJ, we simply make sure it is recorded accurately. The link with Consumer Duty obligations and requirements is in our three main campaigns on Get Satisfaction, Partial Settlements and Claimant Data. Get Satisfaction calls for regulated firms to have the recording of satisfied or fully paid judgments sent through to the courts (and then to Registry Trust) in the same way that firms take out the original judgment. The mechanism for doing so already exists, and does not require structural change for firms, or legislative change for government. What it would do is give firms a way to demonstrate that they were acting in the interests of customers by ensuring they had their records updated when a debt was fully repaid or satisfied. Partial Settlements are not reflected in borrowing history or credit ratings. If a consumer and a firm come to a financial agreement, the consumer receives no public acknowledgement of the agreement, and therefore limited …

Up in the air
When is it appropriate to lend to those with CCJs?

Published 10 October 2022

Earlier in the magazine we asked Lex Jones of the Registry Trust to talk a little more about the importance of the work that they do on county court judgments (CCJs). The CCTA is a strong supporter of their Get Satisfaction campaign to ensure that the judgments are kept up to date. When CCJs are satisfied it is important that there is a record. This should be win win for both the customer and lenders. The guidance around the Consumer Duty makes clear that a lender is looking to deliver the best outcome for a customer when they make sure information is passed along about a CCJ. Looking into the future, the sign that a customer has corrected their position, that they have taken steps to put things right is surely an indication that they may be a suitable customer in the future. From a behavioural perspective, in terms of credit risk, a lender might view favourably someone that has not just let time run down on their CCJ. However, this is only relevant if the regulator doesn’t close lending to those with CCJs. This was one of the issues that emerged from industry discussion earlier in the year. It became a concern that the FCA were questioning if it was right to lend to people that had CCJs. While this was an issue that emerged from informal conversation amongst members, we said at the time that we would pursue this further with the FCA. For us, the concern was that this looked like a misunderstanding of the nature of the market that many high-cost lenders serve. Our view has always been that, especially in sub-prime, customers may well have had a CCJ. In a statement that we were told we could share with the membership we were assured that the FCA’s position is not that you cannot lend to a customer with a CCJ. They said to us, “A firm should have regard to any information of which it is aware of at the time the creditworthiness assessment is carried out that may indicate that the customer is in, has recently experienced, or is likely to experience, financial difficulties. The fact that a customer has a CCJ is likely to be relevant to this assessment.” Hopefully that provides some assurance that there is no outright ban. They went on, “The extent and scope of the creditworthiness assessment, and the steps that the firm must take to satisfy the requirement that the assessment is a reasonable one, based on sufficient information, are dependent upon, and proportionate to, the individual circumstances of each case. The presence of a CCJ may be a factor suggesting that a more rigorous affordability assessment is necessary.” Now the quicker amongst you may realise that this is also not an endorsement of this lending. There is enough in that explanation, with a mention of proportionality, that supervisors could use to close this down while not imposing a full stop. There is also a deeper question as …

Building a framework
Evidencing outcomes in a Consumer Duty world

Published 10 October 2022

The FCA’s new Consumer Duty is a vital aspect of the current regulatory regime. This is a significant regulatory intervention aimed at raising standards. The proposed new principle – ‘A firm must act to deliver good outcomes for retail customers’ and the associated cross-cutting rules represent a clear shift in approach and a significant raising of the bar across the product lifecycle. Where good conduct was once demonstrated primarily through adherence to policies, processes, and rules, the FCA is itself focussing more on outcomes and expects firms to do the same. Rules-based compliance, in isolation, has given way to an outcomes-based approach with the FCA expecting firms, and their boards and senior executives to assess and monitor the outcomes customers receive. A way for firms to evidence against this requirement is to undertake customer-focused outcomes testing. WHAT IS OUTCOMES TESTING? Apart from ‘outcomes’ being the new buzzword (it is used 152 times in the FCA’s final guidance), outcomes testing is still quite a nebulous concept. So what is it? At Square 4, we view outcomes testing as a holistic review of a customer’s journey, to determine whether, based on their individual circumstances, customers received a good outcome. Typically we’ve found a level of direct customer engagement to be most effective. The articulation of the desired outcome should be defined by the firm for each component part of the customer journey, taking into consideration FCA requirements, its defined standards in relation to customer interactions aligned to its customer experience agenda, and its defined risk appetite. It is useful in the design of the outcomes testing methodology to consider regulatory expectations regarding the conduct of business and treatment of customers. However, it is imperative that outcomes testing is more than just a detailed assessment against the FCA rulebook. Upon reaching a consensus on a defined standard, firms should consider the KPIs and tolerances that are acceptable and how they are then going to measure the outcomes. Measuring outcomes can take many forms and would include intelligence around; product usage, customer contact, file reviews, MI from distributors and third-party suppliers, feedback from analytics on digital journeys, complaints, business persistency rates etc. Of these, customer contact is critically important, particularly to test the quality of financial promotions, disclosures, and customer understanding. In designing the Outcomes Testing Framework and methodology, we’d encourage firms to think about some of the key drivers behind the Consumer Duty, namely; the irrational nature of consumers, the behavioural biases they display, whether their products are fit for purpose and provide fair value, the level of financial literacy of their target market, and the imbalance of knowledge that exists between firms and consumers. The Consumer Duty requires firms to put consumers at the heart of their business and focus on delivering good outcomes. To do this effectively, firms need to consistently consider the needs of their customers, and how they behave, at every stage of the product/service lifecycle. With ongoing testing in place, this allows firms to continuously learn from their …

Path to success
An update on membership services

Published 10 October 2022

In the last edition of our magazine, I spoke about some exciting plans to further develop our services as a trade association. This edition presents a good opportunity for me to update our members, both long-standing and those that have joined us recently, on those plans. In short, it has been a busy period for the CCTA team but our plans have progressed well. Last time, I spoke about CCTA introducing more workshops and guidance papers on key regulatory topics. As many of you will know, we delivered the first of those workshops in August, covering the Consumer Duty and the key considerations for our members. It was a hugely successful workshop, attended by over 100 members and we received a lot of positive feedback. Following the workshop, we published our Consumer Duty Guidance Paper, which supported and guided our members in not only understanding the Duty but the key implementation and operational considerations. We continued with in-depth discussions around the requirements and expectations of the Duty at our recent Autumn Summit. But our work on Consumer Duty does not stop there. We know it remains a key regulatory topic, not just during the implementation phase, but for years to come. We are now working on delivering the next set of workshops and guidance papers. Before the end of the year, and going into early 2023, we will be covering key topics such as illegal money lending, online and social media financial promotions, commission disclosures, complaint handling and MI in light of the Consumer Duty and Statutory Debt Repayment Plan (SDRP) scheme, to name a few. In fact, members will have seen the recent release of our second guidance paper on the FCA’s improvements to the Appointed Representative (AR) regime. This is a must-read for our members who have, or plan to have, appointed representatives. Similarly, we previously spoke about a review of all our core regulated and non-regulated agreements and statutory documents, which a lot of members use. Considering the Consumer Duty, we have improved readability, layout, and accessibility. Key financial information, as well as terms and conditions are clearer and aid consumer understanding. We are now at the latter stages of final review and approval, and aim to release the new versions towards the end of the year. Concurrently, we are starting discussions with some potential online training platform and software providers. We previously mentioned our intentions to introduce training and CPD for our members. Although our discussions are at very early stages, we intend to launch compliance training as soon as practicable for member firms and their staff. Our plans are to make available training modules that will cover many of the key legal and regulatory topics in our sector. These include (but not limited to) complaints, financial promotions, CONC, the Consumer Credit Act, treating customers fairly, vulnerable customers, anti-money laundering, anti-bribery, the Consumer Duty, whistleblowing, data protection/GDPR and SM&CR. As we approach the end of 2022, here at CCTA we are already planning what 2023 will …

Trimming the fat
Reform of the Consumer Credit Act

Published 10 October 2022

This year marks what could be a major revolution in UK consumer credit law, with HM Treasury (HMT) in June announcing planned reforms to the Consumer Credit Act (CCA). The CCA regulates all credit cards, personal loans and retail asset finance. The Government will move retained provisions in the CCA from statute to sit instead under the framework of the Financial Conduct Authority (FCA). Firms and consumers alike should keep an eye on these developments. For firms, depending on how the regime takes shape, changes will likely be needed to their systems, front and back books, agreements, servicing arrangements and policies. The aims of the reform are to modernise and simplify the CCA. The Government described the existing regime as “highly prescriptive and increasingly cumbersome and inflexible – confusing consumers and adding unnecessary costs to businesses when implementing its requirements”. The stated intention of moving much of the CCA from statute to sit under FCA rules is to: enable the FCA to respond quickly to emerging developments in the consumer credit market, rather than having to amend existing legislation; and simplify ambiguous technical terms to make clear to consumers what protections they have, and make it easier and more cost effective for businesses to comply with regulation. In the spirit of Brexit and the resulting opportunity for UK regulatory reform, the proposed CCA reform is likely to mark a significant philosophical change to the consumer credit regime, rather than the ‘lift and shift’ exercise undertaken when the FCA took over the regulation of the consumer credit market. The Government has made clear that its approach now will be different, with a view to crafting and creating a consumer credit regime that is more outcomes based and “better suited to the needs of the British people”. There are three key themes of the reform, which build on the recommendations of the FCA’s retained provisions report in 2019 and the Woolard Review. These are: 1. INFORMATION REQUIREMENTS HMT will consult on repealing all information requirements that currently sit in the CCA. The FCA will then consult on handbook rules to sit in CONC that will govern the form and content of pre-contract disclosures, agreements and post-contractual notices (similar to the current regime in MCOB). HMT and the FCA are clear that this will not be a ‘lift and shift’ exercise. Instead, this will be an opportunity to review in detail the relevant requirements and consider what information consumers need, and when and how it should be transmitted to them. As echoed in HMT’s June press release, there is a clear desire to move away from tick box regulation to more principles outcomes based requirements, albeit with recognition and acknowledgment that a certain level of prescription will be required (e.g. for total cost of credit assumptions if customers are to be able to compare products across the market). Clearly there will be significant work involved here for the FCA (and ultimately also for firms). Firms are likely to need to review their origination and …