Improving consumer outcomes
What role does technology pay?

Published 16 March 2023

Designed to ensure higher and clearer standards for consumer protection, the new Consumer Duty regulation requires firms to take decisive action. Despite the initial consultation finding that many organisations were happy to embrace these changes, it was also acknowledged that extensive programmes of work would be required. In fact, the FCA identified thirty firms that needed to do more, with investigations continuing into forty others. Unsurprisingly, this has led to a growing number considering the deployment of specialist technology, designed to improve their understanding of customer behaviour and overall financial health. KEEPING TRACK OF CHANGING CIRCUMSTANCE With the energy price cap expected to rise again this April, thousands of households are at risk of falling behind on their monthly payments. Combined with rising inflation, many are facing an uncertain future. Against this challenging economic backdrop, banks and lenders must prepare for the fact that a person’s circumstances might dramatically change. Tools such as Aryza Recover can provide a real-time picture of a person’s financial situation, as well as alerting them to any changes to their circumstances. The solution takes into account a person’s income, level of affordability and vulnerability, constantly tracking their situation over time. Having partnered with bill-switching organisations such as Uswitch, those using the tool can also help consumers to review their spending and access more cost-effective alternatives. In addition, Aryza’s API can access an Open Banking-driven benefits calculator, allowing individuals to carry out their own thorough and accurate benefit check, as well as flagging any unclaimed benefits they may be entitled to. IMPROVING COMMUNICATION Traditionally, if a person was deemed low-risk, they might only hear from their bank or lender on an annual basis or if they defaulted on a payment. The introduction of the Consumer Duty regulation will force this to change. Through the introduction of specialist technology, organisations can automatically reach out to a person should they notice a change in their circumstances, offering more accessible support and taking a more proactive approach to customer engagement. While there’s no denying that a lot needs to be done before the industry meets the requirements of the new regulation, the technology is certainly available to make the process easier for all those involved.

Fair warning given
FCA expectations in regards to handling BIFD

Published 16 March 2023

It’s been just over three months since the FCA published its report on borrowers in financial difficulty (BiFD) in November 2022. Prior to this report, in June 2022 the FCA published a Dear CEO letter on this very topic, telling more than 3,500 lenders how they expect them to support borrowers who may be struggling due to the rising cost of living, based on the interim project findings. More recently, in his blog published on 6th February, Sheldon Mills reminded how the FCA is working hard to make sure firms treat customers fairly during the cost-of-living pressures. WHAT IS BiFD? The BiFD project to support consumers facing payment difficulties due to coronavirus was launched by the FCA in March 2021. Its aim is to ensure firms are meeting the expectations set out in the Tailored Support Guidance (TSG) and where failings are identified, the FCA are clear – they will use their supervisory and enforcement powers to intervene. BiFD FINDINGS While the FCA stressed that they had observed examples of firms delivering good outcomes, their report urged all lenders to focus on improving outcomes relating to the following: encouraging and facilitating customer engagement ensuring sufficient resource, as well as ensuring staff are adequately trained and experienced providing appropriately tailored forbearance solutions to customers which take account of their individual circumstances effective governance arrangements to ensure there is adequate oversight and quality assurance of forbearance processes in place and the customer outcomes are monitored and achieved effective signposting to free and impartial debt advice ensuring that fees and charges for those in arrears or payment shortfall are applied fairly and only reflect reasonable costs incurred. The FCA reports that this BiFD project included surveying over 400 lending firms, linked consumer research and deep dive assessments into 65 firms. The deep dive process in part involved the FCA reviewing customer files to assess firms’ delivery of forbearance for a sample of individual customers across different sectors. At the time of writing, the BiFD project team reports that 32 of the 65 firms lenders have been asked by the FCA to make changes to improve the way they treat their customers and by November last year, seven had agreed to pay £12 million in compensation to nearly 60,000 customers. NEXT STEPS It would be easy to think that just because you’re not one of the unlucky 65 firms selected from the 400 surveyed to take part in a deeper dive review that you need not act, but that would be ill-advised, particularly in light of the new Consumer Duty, which, while not yet in force, raises the bar on consumer outcomes. The FCA have been clear in their expectations in publishing this report – firms need to consider the contents and take immediate action where necessary. This means making changes and if necessary, remedying any past failings.

Adding to the toolbox
Optimistic collection success: Benefits of offering multiple payment options

Published 16 March 2023

Fuelled by the pandemic, the consumer finance and lending landscape has changed dramatically in recent years. The demands of today’s tech-literate population are higher than ever, and consumers expect a streamlined end-to-end payment experience. With Direct Debit often used as the default payment method, are lenders missing out on an opportunity to grow their customer base and increase conversion by failing to offer alternative payments methods as part of their collections strategy? Given the uncertainty of the current financial landscape, coupled with the shift towards greater consumer protection and a focus on Consumer Duty, lenders now have a unique opportunity to reimagine their collection techniques. CUSTOMER-CENTRICITY With huge challenges facing UK borrowers, lenders should possess a high level of understanding of their customers’ needs and preferences across every channel. When serving borrowers of all ages and payment preferences, the ability to offer payment methods including digital wallets, payment links and Open Banking can help appease a multi-generational customer base. CARD PAYMENT By setting up a Continuous Payment Authority (CPA) lenders can vary payment amounts and the date when payment will be collected. CPA also allows for speedy settlement and live data enables strategic decision-making about borrowers in real time. In line with Consumer Duty, this means lenders have a greater chance of ensuring a successful outcome. Handy solutions like Account Updater can also be used in parallel with CPAs to ensure that customer card information held by lenders is automatically updated, optimising success rates and reducing admin time. DIGITAL WALLETS The convenience and security of digital wallets including Apple Pay and Google Pay makes them an excellent option for ad-hoc collections, particularly for lenders serving a younger customer base. Apple Pay can also be used to tokenise card details for CPAs, making the onboarding process highly efficient. OPEN BANKING Working with a Payment Initiation Service Provider who is authorised to initiate payments directly from customers bank accounts through Open Banking can be transformative for lenders. From a customer perspective this means payments can be authorised efficiently and securely, and from a lender perspective this helps save costs on transaction fees, particularly when dealing with high average transaction values. CONCLUSION When lenders attempt a collection for the first time through a CPA, if the payment fails due to insufficient funds, rather than retry the same method, they could then send a link with the option to pay via Digital Wallet and PayByBank. By allowing borrowers to choose which account they make payments from, or to immediately let you know they’re struggling to pay, not only provides great customer service but also improves customer retention and reduces admin costs. Acquired.com offer alternative payment methods including Pay By Bank, Card payments and Digital Wallets. Get in touch if you are interested in diversifying your payment strategy.

Bracing for impact
ID.VU thought leadership

Published 16 March 2023

Data On Demand take a look at the backdrop of the cost-of-living crisis focusing on the changing impact to consumers, what firms can do to help and what their own insights show. IMPACT ON CONSUMERS The challenges facing firms in 2023 on how best to support their customers will be no less challenging than the ones faced in 2022 which saw a sustained period of volatility and financial stress for UK Consumers. As we move into 2023 that situation will continue to evolve and also to impact new people. Christmas was a welcome break for consumers, but also put further strain on spending with increased cost and for some, unaffordable borrowing. In a poll by the BBC, over a third of respondents who used credit to get through Christmas said they were not confident about their ability to repay. Across November and December we saw over 1.2 million loan applications from consumers for High Cost Credit with a 30% increase on application volumes from 2021 Energy prices were a significant challenge across 2022 and remain so. This meant tough decisions for those with little, or no disposable income who couldn’t afford to heat their homes through winter. Research by Abrdn Financial Fairness Trust suggested as many as 75% of UK households had reduced usage to avoid cost. Over 50% of High Cost loan applications across Q4 2022 were for “household bills”, equating to over £358 million in request support The scale of impact is being felt broadly across the UK and not just by those in a persistent state of financial vulnerability. 2022 saw government support such as furlough drop away as prices increased. This has led to aftershocks as consumers who have been historically financially stable see savings dwindle and disposable income reduce, or disappear completely. Data from the Bank of England shows credit card borrowing hit its highest rate since 2004 and use of Buy Now Pay Later increase as consumers look to alternative means to support their living costs. Over 31% of the applications for High Cost borrowing seen in December were from individuals applying for the first time IMPACT ON FIRMS SERVIING CONSUMERS Some key themes and solutions we have been discussing with clients as they prepare for 2023: Don’t rely on the status quo Volatility brings increased change and risk. To understand how that impacts your customers alternative sources are critical to support BAU process. Be Pro-active Consumers may not feel comfortable speaking to you directly. Prepare to support inbound communication, but focus on how you engage proactively and provide other avenues for them to share problems. Focus on outcomes Do your processes/partners deliver the right outcomes for consumers? Identify areas for improvement.

A look under the bonnet
Automotive finance

Published 16 March 2023

Auto Trader has been authorised by the FCA, with permissions to be a credit broker, since 2016. In 2017, we launched our dealer finance product and now 74% of our retailer partners offer finance products through our platform. We have also offered valuation pricing insights since 2013 and categorise these into retail, trade, private and part-exchange valuation types. With 13,000 retailers advertising over 500,000 vehicles to 10 million consumers each day, as well as almost 2 million finance calculator interactions each month (that’s 45 a minute) our data offers a wealth of insight into consumer behaviour and attitudes towards credit. VALUATIONS As the UK’s number one automotive marketplace, we provide the most robust view of vehicle pricing across the industry. We serve more than 144 million valuations per year, with around 13 million of these to consumers and the rest to the broader automotive industry including retailers, insurance and finance companies, as well as government organisations. Our valuations data has many use cases, from historic valuations used to settle insurance claims, current valuations for those looking to buy and sell, and future valuations which can assist in residual value calculations. THREE KEY TRENDS IN MOTOR FINANCE 1. Used car APRs are up but not as much as new car APRs In January 2022, the average new car APR was 5.1%. This year it jumped to 8.1% whereas used cars have only increased 1.9 percentage points year on year, moving from 9.2% to 11.1% in 2023. 2. Despite this increase, used car finance is on the up In January 2023, there were 42% more interactions with finance calculators on our platform than the same period in 2020. We also saw a 25%increase compared to 2021. 3. A slight shift to PCP in older age brackets, which were historically the preserve of HP At the end of last year, 22% of five year old cars were financed through a PCP deal. PROTECT YOUR ASSETS To deliver an objective and real time service to our customers, we are beginning to source motor finance data directly from lenders. Benefits of sharing finance data with Auto Trader: inform consumers and industry traders of vehicles that you own protect against asset conversion fraud prevent dual financing ensure consumers are being treated fairly and can make informed purchasing decisions. Providing data to Auto Trader is straight forward and free. You can provide data in the same way you currently supply to HPI & Experian. To protect your assets, contact: karan.ridgard@autotrader.co.uk

A step too far
Sheriff Appeal Cour: Alan King V Black Horse + Parks

Published 15 March 2023

The Sheriff Appeal Court (SAC) recently considered whether a hirer under a hire purchase agreement was entitled to rely upon his rejection of a motor vehicle when he had continued to use the vehicle after rejecting it. THE BACKGROUND Black Horse supplied Mr King with a motor vehicle under a hire purchase agreement in June 2019. In October 2020, Mr King sent an email to Black Horse claiming that the car was not of satisfactory quality and was not fit for purpose. Black Horse disagreed and Mr King commenced proceedings against Black Horse arguing that, under section 9 of the Consumer Rights Act 2015 (CRA), he was entitled to reject the car supplied to him. During the litigation in Kilmarnock Sheriff Court, the supplying dealer, Park’s (Ayr) Limited, was brought in as a third party. This was on the basis that, if Mr King was entitled to reject the car, Black Horse would have a right of relief against Park’s. However, Black Horse also argued that Mr King had continued to use the vehicle after he informed Black Horse that he wished to reject it. It was not disputed that Mr King had driven some 6,231 miles in the period October 2020 to November 2021. Black Horse moved for summary decree (judgment) on the basis that the Pursuer was barred (estopped) from rejecting the car because of his continued use of it. The court found for Black Horse and granted summary decree against Mr King. Mr King appealed to the Sheriff Appeal Court. THE APPEAL HEARING The SAC confirmed the long standing rule that a person cannot use goods after rejecting them. In quoting a case from 1898, the SAC noted that to allow a party to reject goods and then continue to use them “would be a very strange theory of law”. The CRA did nothing to change that rule. Whilst the concept of personal bar may apply in certain circumstances under the CRA, such circumstances were not present in this case. In addition, the SAC rejected Mr King’s argument that to impose personal bar on a consumer in these circumstances would impose a significant burden which would be disproportionate and would not be consistent with the CRA, which was designed to give clear and simple rules for consumer protection. The SAC refused the appeal, found that the sheriff at Kilmarnock Sheriff Court was correct to grant summary decree against Mr King, dismissed the action against Black Horse and found Mr King liable to Black Horse in the expenses of the appeal. WHAT DOES THE DECISION MEAN FOR FINANCE COMPANIES AND MOTOR RETAILERS? This is a useful decision for motor finance companies and motor retailers where the vehicle is supplied under the CRA. It confirms that the hirer or buyer cannot purport to reject a car and then continue to use it. Enquiries should be made to ascertain if a consumer is continuing to use a vehicle after seeking to reject it. It will also be interesting to see …

Experiencing technical difficulties
A consequence in the rise of online banking for creditors in Scotland

Published 15 March 2023

Many readers will be aware that a Bank arrestment is a commonly used enforcement tool in Scotland post the granting of a Decree (Judgement) for payment. It allows a creditor to secure any funds (over and above the statutory protected minimum balance) in a debtor or customer’s bank account and can be a valuable recovery option if the timing is right. Service is carried out by Sheriff Officers in person, generally at a local branch of the relevant Bank. The relevant Bank, and indeed any proposed party in whose hands it is intended to arrest funds – requires to be subject to the jurisdiction of the Scottish Courts and this was previously rarely a problem as the vast majority of Banks had branches in Scotland and jurisdiction could therefore be established. However, with the rise of the so-called online challenger Banks, a perhaps unforeseen difficulty has come to light. Such Banks provide all their facilities and services online and through apps on mobile phones and tablet devices. They have no requirement for physical branches. In the last decade or so, there has been a significant shift in how customers are using their Banks and many of the traditional High Street Banks are now reducing their branch presence, in recognition of this shift, and moving increasingly to an online service – no doubt cost reduction is also a factor. Most of the online Banks will have their registered offices outside of Scotland. So what does this mean for creditors? Given what’s been said above in relation to the requirement for a Bank in whose hands an arrestment is to be served to be subject to the jurisdiction of the Scottish Courts, this shift to online Banks is causing a problem. Where a debtor or customer banks with an online Bank and the registered office is not in Scotland, it would seem that it is not possible to serve a valid arrestment. Section 2 of the Execution of Diligence (Scotland) Act 1926 prohibits serving an arrestment by post out with Scotland. This came into force a considerable time before online banking was even thought about and is therefore not fit for modern purposes. I am aware that several sheriff officer firms are now taking steps to raise this issue with their professional body. A change will be required to legislation, and this will likely take some time to be implemented. It does however require to be addressed to ensure those pursuing debts in Scotland have the full range of enforcement options open to them.

An axe to grind?
Safeynet Credit V Impakt Claims

Published 15 March 2023

You may recall the claims management regulator was a unit of the Ministry of Justice and it regulated companies providing claims management services to England and Wales. Its regulatory responsibilities – which lie within the FCA Handbook under Conduct of Business sourcebook – passed over to the Financial Conduct Authority (FCA) on 1 April 2019, and this was recently tested in the case of SafetyNet v Impakt. SOURCEBOOK RULES The sourcebook rules dictate that before a claim is pursued against a firm on behalf of a customer, the claims management company (CMC) must take reasonable steps to investigate the existence and merits of a potential claim. It must also ensure that its customers/clients have provided their consent and the relevant authority for the CMC to represent them. THE FACTS Impakt, a CMC, was well known for raising complaints on behalf of customers against various lenders. Impakt has brought claims against lenders for providing customers with loans but had either failed to carry out adequate financial assessment of their customers or conduct proper creditworthiness checks. SafetyNet was one of the lenders Impakt pursued and brought a number of claims to SafetyNet’s door. SafetyNet stated that it had received more than 5,330 claims from Impakt and 2,871 data subject access requests and, out of those investigated, it accepted 247 claims in April 2021 due to the FOS’s eight weeks deadline in dealing with complaints. Due to time constraints, SafetyNet failed to investigate claims in-depth. Resulting in pay outs of approximately £100,000. In 2022, SafetyNet brought a claim against Impakt alleging huge losses – in the region £440,000 – due to the volume of complaints Impakt lodged with the business. This resulted in wrongful pay-outs to customers, loss of business plus the expense of training staff to manage the volume of such complaints. It also alleged that Impakt had other failings, including the failure to assess and investigate the claims properly, the fact that many of the claims that were submitted had insufficient or no oversight and some claims were lodged without the customers’ consent which led to breaches of the Conduct of Business rules. Impakt rejected these allegations. Impakt claimed that SafetyNet could have asked for an extension of time to investigate the complaints if needed, which it failed to do. It therefore claimed that it was entirely down to SatefyNet and its own procedures that inevitably caused the losses. Impakt has requested a declaration so that it can continue to pursue the outstanding claims. It has put in a claim for damages of approx. £100,000 since SafetyNet has paid out customers directly and has not received the fee share Impakt has agreed with its customers. This case is with the High Court to decide on the outcome and the result is eagerly awaited by lenders and, no doubt, CMCs. ADMINISTRATION FOR SAFETYNET However, the claimant SafetyNet went into administration on 9 January 2023. As the matter is still with the court, the company may not have sufficient funds to continue with …

An eye on the ball
Ongoing issues outside of Consumer Duty

Published 14 March 2023

There is no doubt that Consumer Duty has been our primary focus for over a year now, and you will have heard about the activities, events, and engagements we are carrying out to support our members with the Duty. However, I want to move away from this for now and update our members on other key regulatory and legislative matters that we have also been progressing. As your trade association, we continue to focus on issues and concerns which are important to our members. Over the course of last year, and as we move forward in 2023, we have continued to address some reoccurring matters, as well as new ones. One of those matters is Claims Management Companies (CMCs). Members have long been frustrated with certain CMC practices and tactics. As such, we have provided support and guidance in this regard. You should have seen a number of updates and communications on this topic from the CCTA. Your experiences and input have been vital in our dialogue with the FCA. I want to move away from (the Consumer Duty) for now and update our members on other key regulatory and legislative matters that we have also been processing. They have helped us raise our concerns about some CMCs, and consequently, we were pleased to see that the FCA recently issued a Portfolio Letter to CMC firms, highlighting some of the concerns we have been raising. So, continue to speak to us about what you are seeing and experiencing with CMCs. We know that, like us, many members were frustrated to hear that the Financial Ombudsman Service (FOS) decided that they would not be looking into charging CMCs for the use of FOS services. Despite this, we have continued our push in this regard in face-to-face meetings with them. It is somewhat of a relief that they have agreed that they will not completely close this matter for now. Another key topic that has opened up dialogue across the financial services industry is the reform of the Consumer Credit Act 1974. Through our usual communication channels, members will be aware that the government launched the first consultation at the end of 2022. Although legislative change may take years, the consultation asks for initial arguments for and against moving some provisions into regulation and retaining other provisions under the legislation. We are working closely with our legal associates to fully understand all the operational, cost, and benefit (or adverse) impacts of the proposals for members. In formulating our response, we are working to ensure that any reform is appropriate, less burdensome, and less complex for both consumers and businesses. Members are encouraged to get in contact as we are keen to hear your initial thoughts on the proposals. At this point, I would like to move on to an area that affects us all, the cost-of-living crisis. Inflation and economic uncertainty continue to add strain on individuals and families everywhere. Through dialogue with many of our members across all sectors, we know …

Looking ahead
Third year plans with our chief executive

Published 13 March 2023

I recently received a notification on social media that I had passed my second anniversary as Chief Executive of the Consumer Credit Trade Association. It came as a little bit of a surprise as the time just seems to have flown by. Looking back, when I took over from Greg Stevens, it was important that we continued his work of advocating on behalf of our members. The CCTA’s mission for over a century has been to protect access to credit and understand the benefits that credit can deliver. Our vision has long been to ensure responsible credit for all and that has been at the heart of our conversations. I am the latest in a line of CEOs that has made that part of my mantra. We also wanted to add value, so we took the existing work of the CCTA and added new elements. Over the last two years, we have established further channels of communication. We have ongoing discussions with the Financial Conduct Authority, Financial Ombudsman Service and HM Treasury. Through these discussions, we have been able to talk about a range of issues. We have made clear that members need more information to help with the implementation of Consumer Duty. We have tried to explain the implications of the focus on affordability. There are many other issues that we have placed on the agenda. The CCTA’s mission for over a century has been to protect access to credit and understand the benefits that credit can deliver It has been interesting how during this economic downturn, the knee-jerk reaction of some is to say that we need to switch off the supply of credit. I agree that consumer credit is not always the answer. However, there are still cars that need to be bought to get people to work. Families have back-to-school costs. These are essentials and consumer credit plays its part. So, in much of our advocacy work over the last two years, we have been explaining how modern credit products can facilitate those bigger spends as well as managing cash flow. Credit is not the answer for dealing with longer-term financial issues with levels of uncertainty. It can be used to manage those temporary, expected, and unexpected peaks and troughs in finances. It can be used to buy those items that will make life easier or open up new opportunities, such as getting to a job that is not accessible through public transport. It has been interesting to make these arguments and represent CCTA members. One of the advantages of being a member of a trade association that covers some inter-connected sectors is that you can draw from the experience of one and use it in another. For example, our experience with complaints places us in a better position when the attention of claims firms move to another part of our membership. We can see some issues emerging that might be future problems for others. I confess that I need to learn and understand more of …

Challenges ahead
Debt and the cost of living: Three ‘must adopt’ strategies

Published 10 March 2023

As we enter 2023, there has been a discernible shift in the conversation around the UK’s cost-of-living crisis. Increasingly, the focus is on a subject we know all too well: household debt. From debt advice charity StepChange warning it will take years for Christmas borrowing to be repaid, to NatWest announcing it will extend the amount of time customers have to repay unsecured loans or overdrafts by six months – lenders and collection businesses are being forced to ask some tough questions. As Chris Leslie, CEO of Credit Services Association (CSA) puts it: “The squeeze on available income after accounting for essential expenditure is still set to get worse in the coming year – which in turn will raise the number of households in deficit budgets and make the collections challenge harder still.” At Lantern, we’ve been reflecting on the trends we’ve seen over the past year and how we should approach the challenges ahead. We’ve distilled these reflections into three ‘must adopt’ strategies for lenders and debt collection businesses. STRATEGY #1 (LENDERS) Improve ‘up-stream’ care of vulnerable customers Some lenders have a mixed record when it comes to effectively categorising and looking after customers who are truly vulnerable and unable to pay. The temptation has often been to offload non-performing debts to collection businesses – but in the current crisis, they should consider some tough questions around their duty of care. Sonex Financial (part of the Lantern Group) – a specialist white label service, helping lenders look after vulnerable customers in a bespoke fashion, are seeing first-hand lenders’ response to the cost-of-living crisis. According to CEO Stefan Russell: “It’s crucial for conversations to be held by the right people, who can empathise with the difficulties faced by customers in today’s climate. Having a team who understand and can relate to the challenges is important for building trust and long-term relationships with customers, to provide a caring, effective and compassionate customer service for as long as it takes”. STRATEGY #2 (COLLECTION BUSINESSES) Prepare to be flexible and patient on repayments The cost-of-living crisis has been part of our day-to-day conversations with customers for the past year. Overall, we’re not seeing significant reductions in repayments – with customers choosing to reduce spending in other areas and preferring to maintain their existing, affordable repayment plans. From Lantern’s perspective, this can be explained by the fact that many of our customers are already in vulnerable circumstances, with repayment plans forming only a small proportion of their net disposable income. These customers are naturally resilient when it comes to cutting back household spending, generally used to very tight budgeting in their day to day life. Across the wider collections industry, there are stories of fewer payments in full or settlements, as customers choose to hold back on using savings accrued during the pandemic. This is also potentially an indication of a new kind of customer experiencing debt for the first time – one that should push lenders and collectors to ask the honest question: …

Can’t see the wood for the trees?
Enhancing clarity in debt consolidation

Published 09 March 2023

Customers with existing credit (whether loans, credit cards or hire purchase deals) are frequently targeted with tempting promotions for 0% introductory deals or personal loans with lower APRs than they currently pay. Debt consolidation solutions can be hugely beneficial to some customers who struggle with their monthly debt repayments, a situation likely to worsen if the pressures on the cost-of-living increase. However, whilst consolidating debts can make monthly budgeting easier or may mean a customer pays lower APRs, these are often accompanied by a significant increase in the overall amount the customer repays. It’s not unreasonable to assume, particularly as the regulatory landscape continues to evolve, that the FCA may expect improvements in customer journeys and increased clarity in the information presented to customers. This not only includes the monetary benefits of consolidation, such as a lower monthly repayment or a lower APR, but also the salient disadvantage of how much larger a customer’s overall indebtedness may become. It would not be ‘disclosure for disclosure’s sake’, but an evolving step in helping the customer work out whether any proposed consolidation may be in their best interests. At first glance, it would be easy to assume this is a straightforward decision for a customer in problem-debt. However, they might benefit more from seeking debt-advice rather than simply re-borrowing. If the FCA’s expectations do evolve in this area, the crux is likely to be on achieving balance at all stages of the customer journey. This includes ensuring the customer is aware of the risks of consolidation whilst not being actively discouraged from something which has the potential to make monthly budgeting easier. APPROACHING LENDERS If a customer approaches a lender directly, for example when seeking an unsecured personal loan from their current account provider, it should be a reasonable expectation that the lender sets out an individual, tailored quotation, including the overall cost of servicing any new debt which the customer may enter, and how the overall cost of the new borrowing compares with the customer’s existing debt. Doing this will never be straightforward, as the lender would have to make a series of assumptions, including on the stability of future repayments a customer may make on their existing borrowing, and on the stability of future interest rates in any existing variable-rate credit products. This information, even if only illustrative, would help the customer make an informed choice about whether to enter the new borrowing to repay existing credit, retain their existing debt, or seek alternative debt-solutions. The provision of information at this level could be a future expectation from the regulator, and one which firms should consider now. Frequently, customers do not make a direct approach to a lender – at least not without having first used price-comparison platforms, eligibility-checking services, or other more traditional forms of credit brokers. By the time a customer submits a ‘final’ application (i.e. a hard-credit search in the anticipation of entering into a specific regulated credit agreement), they could have already gone through a series …