What would be in the CCTA Manifesto?

Published 02 July 2024

As we head towards polling day for the general election on the 4th of July, we have now seen the manifestos from all the main political parties. The purpose of a manifesto is to outline the steps a party would take, if they get the opportunity to form a government. From what we have seen most of the 2024 manifestos have been light on the detail around consumer credit and financial inclusion- understandably there are other issues that grab the headlines like NHS waiting lists and illegal migration. But this has led us to think about what we would put in the “CCTA Manifesto”. What would the CCTA be calling for from the next government as the main trade association representing alternative lenders? Firstly, access to credit has been central to the CCTA since its creation in 1871 so it’s not surprising that we would want the future government to address the sharp contraction we have seen in the alternative lending market. We don’t have enough lenders to provide credit to poorly and under-served communities. Lenders have left the market in recent years, and new firms have not entered it. There has been a sharp rise in illegal lending. We would be happy to work with any organisation looking to address the issue of access to credit. We are also looking for a more positive narrative from policymakers when talking about the sector. Taking the points above, we need them to accept where we are publicly. They also need to discuss how the future will involve lenders who are Consumer Credit Trade Association members. Though we all support the growth of community lenders and Credit Unions (indeed they form part of the CCTA membership) they cannot alone fill the gap left by commercial lenders. A more positive narrative from policymakers would reassure and encourage investors and new entrants. We will work to help government understand the non-prime customer. The CCTA is also supportive of more regulatory certainty. FCA rules are open to interpretation, making it difficult for lenders to know where they stand. In recent times we have been working with the CCTA members to better understand FCA’s expectations. This is particularly important for smaller firms. Focusing on SMEs, the CCTA is made up of a range of small and specialist lenders. We would ask for the government to understand the additional regulatory burden that falls on these firms. There is also a need to ensure these firms can access funds and basic banking services moving forward. We would also call on the next government to address the current claims culture. Claims management companies (CMCs) have had a big impact on the alternative lending sector in recent years. The FOS’ current consultation on charging CMCs to access their service is a welcome step but the next government must ensure that this change gets over the line and allows the necessary parliamentary time. If not, CMCs will continue to exploit different sectors of the market and continue to deliver poor outcomes …

FOS consults on charging CMCs

Published 10 June 2024

A general election wasn’t the only announcement we saw in late May. The Financial Ombudsman Service (FOS) also published its next consultation on plans to move forward with charging professional representatives, including Claims Management Companies (CMCs), to access their service. We, along with many CCTA members, responded to the last consultation calling for action to be taken. The FOS are consulting on a £250 case fee charge for CMCs. If a CMC wins a case, that would be reduced to £75. If the CMC loses, the £250 would be used to reduce the lender’s fee. CMCs will be allowed three free cases a year, like all other financial services firms. The service remains free to those who bring their case directly to FOS as well as families and friends, charities, and voluntary organisations who may be helping them. We welcome plans to move ahead with charging CMCs but don’t see why they would be treated any differently from lenders. For that reason, we think the full case fee of £650 should be applied to CMCs when bringing a case to the FOS. We are supportive of the principle that there could be some form of discount in the fee if the CMC is successful in their case. Over the last two years, over 20% of cases referred to the FOS have been brought by professional representatives. Of these cases, fewer than 25% result in a different outcome for the complainant than they have already been offered by the responding firm. The consultation tells us that consumers achieve a better outcome when they complain directly, rather than using a CMC. (32% of consumers bringing their case without representation achieve a better outcome). Obviously, we want to address the unfairness of the system but hopefully improve CMC behaviour to deliver a better experience for consumers too. And there is also a role for the wider industry to play in educating consumers that they do not need a CMC to represent them. Where complaints are upheld, CMCs and professional representatives take a significant proportion of redress awarded to their clients. Consumers would keep the full value of any redress awarded if they brought the case to directly to the FOS. These companies can send in large volumes of cases with little prospect of being upheld and they are often poorly presented. This can have a significant impact on the FOS’s ability to help others who have come directly, and drives up the Ombudsman costs. For too long these firms have been able to submit claims of a poor nature, because win or lose the lender will have to pay the case fee. The CCTA has been calling for change over recent years with HM Treasury, the FOS and the FCA.  The introduction of a fee should act as a deterrent for firms to submit poor quality claims and reset the balance. We will be responding to the consultation and working with CCTA members on their responses. The consultation closes on the 4th of July. …

The general election and a possible change in government

Published 30 May 2024

On the 22nd of May, Rishi Sunak surprised most of the UK by calling a General Election to take place on the 4th of July. Much of the political world thought it would take place in the autumn, but there was a growing sense that this was as good as it would get for the Conservatives. Though polls can be misleading and often narrow as election day approaches, Labour has consistently been around 20 points ahead of the Conservatives. It seems unlikely that the Tories will feature in the next government. Labour looks likely to be at the head of the next government in some form, possibly with a majority, a minority, or a coalition arrangement.   What would a Labour government mean for the alternative lending sector? Labour has said very little that would worry or calm the sector. We believe they may attempt to get through this campaign by saying as little as possible. The more it reveals its policies, the more the Conservatives can attack. In the few relevant statements, they have picked up on concerns about Buy-Now-Pay-Later. After pointing out this government’s regulatory delays, we can assume that they will want to move quickly. They have also addressed concerns about access to credit as part of a wider discussion on financial inclusion. They may also consider introducing a Fair Banking Act that would require the High Street banks to either lend directly to unserved communities or provide funding to other lenders that serve those groups. This has had some impact in the US so they may look to replicate something similar. Elsewhere, Labour has been careful to welcome the changes brought by the Consumer Duty but joined others in criticising the FCA, where the regulator has been more aggressive. They have floated the idea of more scrutiny. Earlier this year, Labour published “Financing Growth”, outlining some of its plans for financial services. This was seen as an outstretched hand to the City. The party is keen to appear pro-business and shed the views of the Corbyn era in this election. At a high level, the paper called for growth and the need to increase international competitiveness, recognising the importance of the FCA’s secondary objective. The report also discussed the need to embrace innovation and fintech, such as AI and Open Banking, with appropriate protections for the consumer.   What does the election mean for the review of the Consumer Credit Act? The future of the current review of the Consumer Credit Act is uncertain. Work on the reform has been placed on hold as we enter the election period, and it’s unclear whether or when this might restart. Labour has previously said that the Act requires updating for the digital age, so they may well continue with the review, but the election will introduce more delay into the process.   What is happening elsewhere? Beyond the Labour Party, there has also been some relevant activity in Parliament. Before the election announcement, the House of Lords Financial …

CCTA comment on new report from Fair4All Finance

Published 23 May 2024

Commenting on Fair4All Finance’s new report “Access to credit & illegal lending”, the CCTA said: We welcome the publication of today’s report, which outlines the current state of access to credit for many and the impact of illegal lending. They are right to point out that the shape of the market is as important as its size. They are also right to say that the UK credit market is not functioning properly for lower income households, many of whom have lost access to credit. We have been trying to draw attention to these issues for some time, having seen the major contraction[1] in the alternative lending sector. This has pushed people to less desirable options. There needs to be more support for tackling illegal money lending, especially as criminals look to use digital channels to exploit more victims. There is also a need to increase legal options. For that reason, it is good to see that the report states that a refreshed high-cost credit market can provide access for some consumers. There is also recognition that community finance alone cannot fill the gap left by commercial lenders. The market needs a range of small and specialist lenders to meet demand and provide competition. One of the report recommendations is about the need for regulatory adjustments to improve the market. Fair4All Finance is calling for a rebalancing between customer protection and the need to provide access to credit. The regulator and industry must discuss how to achieve this to ensure access to legal, regulated credit for those who need it the most. [1] From being 4% of the outstanding consumer credit loans market in 2013, forms of legal, high cost credit reduced to under 0.3% by 2023 (Fair4All Finance). Industry estimates that this is a fall of about £3 billion.  

Treasury Committee looks at the issue of de-banking

Published 20 May 2024

Earlier this month the influential Treasury Select Committee published their report into SME Finance. The Committee contains MPs from across the House of Commons, representing all major parties. The report was commissioned to look at the recent experiences of small businesses. It was designed to consider the issue of access to finance and what else can be done to encourage business growth. The last few years have been tough for small businesses across all industries. Rising inflation has had a severe impact on costs, and a global pandemic changed things for everyone. That said, SME firms make a substantial contribution to the UK economy which should not be undervalued. For that reason, we cannot ignore that SMEs are struggling with narrow access to finance, in the face of these rising cost pressures and higher interest rates and are generally pessimistic about their ability to raise funds. Many report struggling to attract new investment for their businesses. The parliamentary committee found that small firms are being put off from innovating and growing by damaging financial regulations and inadequate support from banks. We are particularly interested in the issue of de-banking. Within the CCTA, we know that many smaller members have struggled with access to financial banking facilities. Pawnbrokers have had a particularly bad time with the issue of de-banking. Perhaps unsurprisingly, the Committee found that over 140,000 SME had their accounts closed last year. We know that access to investment and banking services are lifelines for any business. The Committee has recommended that any small business doing legitimate work should have access to a bank account. The Committee members heard that many accounts were closed because they fell into “undesirable” sectors. Pawnbroking was included here, despite being a service that has been provided for hundreds and years and helps those individuals that struggle to access finance themselves. As a result, the Committee is calling on the Financial Conduct Authority (FCA) to force banks to be more transparent about why decisions to de-bank businesses are taken. The FCA should also continue its work to better understand criteria for account closure. Committee members also believe the regulator should compel firms to send them the number of business accounts they’ve closed each quarter split by reason. The Treasury has assured the Committee that legislative changes will be introduced to crack down on the de-banking of businesses in the form of a Statutory Instrument. When questioned, the Economic Secretary Bim Afolami MP, and Treasury officials, said that the planned changes to termination rules would apply to business accounts. The plans also include extending notice periods to 90 days and having to give a clear reason for closure, except where it would be unlawful to do so. The Treasury is expected to publish regulations soon. It is good to see the Treasury Select Committee shining a light on these issues. The CCTA will engage with Treasury officials at our regular meetings to ensure the publication of the new rules is not delayed. If members have had …

Technology – the pace of change is rapid

Published 07 May 2024

Developments in technology have been back in the news in recent weeks. Open Banking, the use of data and AI have all received mentions. Though they offer exciting possibilities, these new developments need to be balanced with the appropriate checks. We are all aware of the potential unintended consequences and the lag that can occur between innovation and necessary regulation. Taken with the importance of protecting the customer and their data, it is not surprising that we have seen the FCA sharing its views on these topics. Firstly, the regulator published its Feedback Statement on potential competition impacts from the data asymmetry between Big Tech firms and firms in financial services. In its overarching strategy, the FCA is committed to identifying potential competition benefits and harms from the Big Tech firms’ growing presence in financial services, hence its research in this area. One area of concern was that the asymmetry of data between Big Tech firms and financial services firms could have significant adverse implications for how competition develops in the future. However, so far, the regulator has found that no significant harms have arisen from data asymmetry, while they work on starting to develop a regulatory framework that enables increased competition and innovation. The FCA will continue monitoring Big Tech firms’ activities in financial services. Depending on the outcome of this monitoring, the FCA plans to develop proposals for consideration in the future. Firms should also be following developments. Elsewhere we saw an update on AI from the regulator. This followed the Government’s response to its White Paper: A Pro-Innovation Approach to AI Regulation which noted the rapid growth in the use of AI and the need to develop a pro-innovation regulatory framework. The FCA has said that it wants to promote the safe and responsible use of AI in UK financial markets and leverage AI in a way that drives beneficial innovation. Their focus is on how firms can safely and responsibly adopt the technology as well as understanding what impact AI innovations are having on consumers and markets. Interestingly, the FCA has also talked about the role AI may play in regulating the financial sector. For example, it could help identify fraud and bad actors. The FCA plans to invest in technologies to monitor regulated markets. Finally, there was a speech from Nikhil Rathi, FCA Chief Executive, which picked up a lot of these themes. He talked about the need to lead a co-ordinated and effective effort to make the most of the opportunities of Big Tech – whilst mitigating the risks. He said the FCA needs to remain vigilant about data asymmetry or risk putting off incumbents and innovators from retail financial services. Rathi mentioned that the FCA is examining the case for developing a commercially viable framework for data sharing in Open Banking and finance. Open Banking remains a central focus for future development in financial services. Through all these developments you can see that the FCA is keen to embrace new technology whilst making …

FCA publishes Financial Lives Survey 2024

Published 15 April 2024

Last week the FCA published the findings of its Financial Lives Survey on the cost of living, conducted this January. The FCA uses the survey to explore the finances of UK consumers and how they would assess their own situation. The survey was carried out between December 2023 and January 2024, with under 3,500 respondents. The regulator reported that 7.4m people were struggling to pay bills and credit repayments in January 2024, however this is down from 10.9m in January 2023. This is a positive step in the right direction, but this is still higher than the 5.8m recorded in February 2020, before the cost-of-living squeeze and the Covid pandemic began. Though it appears that the cost-of-living crisis has not been as bad as some expected, over 5m people still said they had fallen behind or missed paying one or more domestic bills or credit commitments in the previous 6 months from January 2024. To counter act this most people (77% or 40.5m) spent less or worked more to make ends meet. Despite high interest rates, 50% of renters (over twice the proportion (24%) of mortgage holders) reported they were not coping financially. Renting continues to be of high cost and a struggle to many. A key objective of the CCTA is to protect access to credit. The survey didn’t really explore the credit options people had available to them but it was interesting to read about the reasons people cut back on essentials. One percent of people reported prioritising paying back a loan from an unlicensed money lender or another informal lender. A figure we know is often under reported. Also, another four per cent reported they were prioritising paying back family or friends. We also know that the line between this form of borrowing can be blurred with illegal lending. The Illegal Money Lending Team has reported in recent times that around 60% of clients believed the loan shark to be a friend at the point of borrowing. In the 12 months to January 2024, 2.7m adults also sought help from a lender, a debt adviser or other financial support charity because they found themselves in financial difficulty. Nearly half (47%) of those that sought help said they were in a better position as a result. The FCA has used the survey as an opportunity to remind firms of their commitments to their consumers. The regulator has announced that its tailored support guidance, introduced in the Covid-19 pandemic, is to be transferred over to the FCA handbook. The new rules include: expanding protections beyond customers who have already missed payments, to those at risk of payment difficulty widening the forbearance options firms should consider enhancing expectations around customer engagement and providing information including on money guidance and debt advice requiring credit firms to consider customers’ individual circumstances when providing forbearance As we have said previously, dealing with customers in financial difficulty or those with vulnerable characteristics remains a central aim of the FCA. Firms should always be referring …

FOS Annual Plans and Budget published

Published 08 April 2024

Last week, the Financial Ombudsman Service (FOS) published its final Plans and Budget for the forthcoming financial year, following a consultation that closed in January. This process takes place annually and allows for firms to feedback on plans the Ombudsman around the complaints process, and how the FOS intends to improve it. This year the FOS consulted on plans to lower fees and operational improvements. It also asked about plans to move forward with charging professional representatives, including claims management companies (CMCs), to access the Ombudsman service. Firstly, there was good news in that the FOS has decided to move forward with lowering the case fee to £650, a drop of £100 per case. They have also confirmed reductions in the compulsory and voluntary jurisdiction levy costs. This is something the CCTA has campaigned on in recent years, so it is good to see a step in the right direction around reducing the regulatory burden placed on firms. We have long argued that that is has been particularly intense for small and medium sized firms, and those that have been affected by the activities of claims management companies. It is disappointing then that the Plan doesn’t cover feedback about plans to charge professional representatives including CMCs, to access the Ombudsman service. The CCTA and several members responded to the original consultation outlining their support to move forward with charging. The FOS will now be publishing a further consultation on charging professional representatives which will outline the feedback they received and discuss next steps during the first quarter of the 2024/25 financial year. It is troubling that these plans have not moved further forward. The status quo means that there are incentives to submit complaints, regardless of the quality. We have all seen that upload rates for complaints brought by CMCs are much lower than when raised directly by the customer. So, consumers are affected by this delay also. We have written to the FOS CEO to outline our concerns around the progress of charging professional representatives. There is a danger that CMCs continue to exploit the system while the process rolls on. Especially when the expected consultation might propose a deadline for charging, or a new system which sees CMCs barrage lenders ahead of implementation. For too long these firms have been able to submit claims of poor quality, because win or lose the lender will have to pay the case fee. The reduction is in the case fee is welcome but still represents a fee of £650. This remains a huge burden on lenders. Consumers also continue to suffer as claims brought on their behalf by these firms are often not substantiated. It is time to take action to improve a system that is meant to assist those that have been treated unfairly.

Vulnerability must remain a central focus

Published 26 March 2024

We have written a few posts in recent months exploring the cost-of-living crisis, and the impact it is having on different consumers. Money worries continue to get a lot of coverage in the media, but we are also told about the recovering economic health of the country. It is difficult to assess how individuals are coping as it is dependent on their own unique circumstances. That said many are still struggling or could easily be affected by an unexpected shock to their income. Though financial difficulty is not the same as vulnerability, the two are inextricably linked, especially in the eyes of the regulator. The FCA has the issue of vulnerability firmly in its sights and it wants to ensure regulated firms are doing the same. Of course, someone could be considered vulnerable for nothing to do with their financial situation – they may have a disability or have suffered a significant life event. Firms should know they need to consider all possible angles. Only last week the regulator announced a review of firms’ treatment of customers in vulnerable circumstances. In its 2022 Financial Lives Survey, the FCA found that over 27M adults in the UK showed at least one characteristic of vulnerability. That is a significant proportion of the population. It is easy to see why the regulator is maintaining such a focus on vulnerable customers. The FCA’s review will look at firms’ understanding of consumer needs, the skills and capability of staff, product and service design, communications, and customer service, and whether these support the fair treatment of customers in vulnerable circumstances. It will also look at the outcomes consumers in vulnerable circumstances receive and whether they’re as good as the outcomes of other consumers.  As part of the review, the FCA will conduct consumer research as well as gathering information from firms and consumer representatives to make this assessment. Firms can be expected to be contacted and be asked to evidence their policies and procedures. This week a “Dear CEO letter” was also issued by the FCA to much of the consumer credit sector further underlining the need to consider vulnerable customers. The letter covered the entire lending cycle but urged lenders to lend responsibly and sustainably. They pointed to the fact the vulnerability is increasing while financial resilience decreases. With that in mind firms should ensure they are following the regulator’s guidance on fair treatment of vulnerable consumers. The introduction of the Consumer Duty should also help firms assess how they are dealing with vulnerable customers. It is about being proactive, stepping in when you can to help and support the customer. “Doing the right thing” for the customer might sound cheesy but a lot of this is common sense. Are you treating the customer like you would want your family to be treated? Are staff alert to the signs of vulnerability? Do you have systems in place to support customers that need it? These are the sort of questions firms should be asking themselves and …

 The Budget – Do the sums add up for UK families?

Published 07 March 2024

Yesterday the Chancellor delivered the Spring Budget in Parliament. The purpose of the budget is to update Parliament on the state of the economy and to outline the Government’s proposals for changes to the tax system. This was arguably the last big economic event we will see from this Conservative government. The Prime Minister has told us to expect an election by the end of this year, so it is unlikely we would see another statement before then. It goes without saying that there was a lot riding on this budget. The Conservatives will be hoping that the measures announced start to move the dial on their current ratings in the polls. Labour still maintains a significant lead. This was about appealing to potential voters. There were numerous mentions of the Conservatives being the party of lower taxation, trying to drum the message home. The big headline announcement was a further cut to national insurance. Someone earning £25,000 a year will save another £249 a year from the latest drop. This will be a welcome change for the average earners across the country, following the previous cut last November. But Sunak (when Chancellor) had previously pledged to take a penny off income tax by 2024, which hasn’t happened, so represents another broken promise. A further welcome announcement was the plan to extend child benefit to more families by raising the income level at which people start being charged for receiving the benefit. The budget included very little mention of pensions so did appear like the Government was trying to appeal to the working-age section of society. During the delivery, Jeremy Hunt said the economy was improving, having “turned a corner on inflation”. That said, there were still a range of pledges to help struggling families. These included the extension of the Household Support Fund for six months, and a longer repayment period for budgeting loans which can be used for essential items like furniture or white goods for those eligible. These proposals will help those hit hardest by the cost-of-living crisis, but no further long-term support was announced. Though the Chancellor did state that he was removing the charge on Debt Relief Orders. A welcome step for those trying to repay debts that they are struggling with. Fuel duty was frozen again, recognising the importance of not increasing the costs of keeping a vehicle running, a lifeline for many families in terms of getting to work, school and keeping businesses moving. Another welcome step was the announcement that vehicle leasing companies will benefit from full expensing with draft legislation expected soon for full expensing to apply to leased assets, representing a significant tax break. We also saw a commitment to green investment with a fund of £120m for green energy projects. Overall, a mixed bag of announcements. The Chancellor was keen to appeal voters, and historically the last budget of a government promises the most in real term gains. He may also be thinking about his own political legacy. Whatever happens at …

Is the cost-of-living crisis over?

Published 20 February 2024

Over the last few weeks, we have seen a lot of news pieces and data released about the country’s financial health and the associated impact on households. Inflation, recession, borrowing, spending, they have all been mentioned. Another phrase we have heard a lot in recent times is the ‘cost-of-living crisis’. We have been told we are in a cost-of-living crisis. A global pandemic that changed the employment status of many and war in Ukraine, causing energy prices to go sky high, resulted in many people struggling to manage their finances. To ease the burden, the Government offered support with the cost of energy, and others also qualified for separate cost-of-living payments to get through a hard winter. It’s unlikely the Government would have provided this level of support if it didn’t expect people to hit crisis point. Last week the final cost-of-living payment was paid to millions. The Prime Minister used it as an opportunity to say that the pressures were starting to ease, due to falling inflation and tax cuts. No further payments of this kind have been scheduled. Inflation might be starting to come down but it stalled at 4% in the most recent figures. It doesn’t yet feel like the economy is improving at any great scale. Last week it was also reported that the country just dipped into recession in 2023, blamed on people spending less – though apparently the figures suggest it won’t last for long, it does appear that there is very low growth. There was some good news however, as food prices have started to fall. Where does this leave family finances? There are some green shoots of good news like wages starting to rise, but at the same time debt advice providers are reporting high numbers of individuals that use their services are really struggling. New research published by Citizens Advice claims that politicians are burying their heads in the sand as five million people now find themselves in a negative budget situation. A significant proportion of society still doesn’t have enough money to make it through the month. It feels like there are now conflicting views on whether the worst is over for many, or that there is still more pain to come as individuals move off fixed rate mortgage deals and expected rises in council tax. Interest rates remain high in the hope that inflation will drop. It’s no surprise politically that the Government is telling us that things are getting better. It will be interesting to see what the Spring Budget entails early next month especially as election looms in the not-too-distant future. The Covid-19 pandemic and the introduction of the FCA’s Consumer Duty have shown that the regulator expects firms to really understand the financial position of their customers. At time when some families are struggling more than others, it demonstrates, more than ever, the need for an individual approach. It is fair to say that while things are starting to improve for some, times remain hard for …

Next steps on the Consumer Duty

Published 09 February 2024

We are now into the seventh month since the implementation of the Consumer Duty. We know that many firms continue with their efforts and focus on meeting the requirements of the Duty and achieving improved consumer outcomes. No doubt firms will agree that it has been an intensive journey thus far. It was always meant to be about delivering continuous improvement in customer outcomes, but now is also an appropriate time to remind firms of the upcoming requirements as to the next steps in that journey. We specifically refer to two requirements which should be addressed by 31st July 2024. The first year of the Consumer Duty implementation focused primarily on new and existing products/services that financial services firms offer to retail customers. Closed products (i.e. products/services that are no longer marketed or sold, but active arrangements still exist) were due to be brought into scope a year later than new and existing products. That deadline is 31st July 2024. Some firms will have already progressed work in this area and will be well on their way to complying with the requirements for closed products, when they are brought into scope. However, for those firms that still need to carry out additional work in respect of their closed products, there is still time to ensure that you have addressed the requirements by the end of July. The next requirement is in relation to firms’ annual board reports. The FCA’s Policy Statement also sets requirements for firms to produce annual board reports for the board (or governance body) enabling the board/body to assess their compliance with the requirements of the Duty and whether they are achieving good consumer outcomes. Annual board reports should comprise of data and insights (MI) from all areas of the business (i.e. product design/development, marketing, sales, customer service, complaints etc) to provide an overall view of the firm’s compliance with the requirements of the Duty. Reports should also enable the board/governance body to identify where good/intended outcomes are not being achieved, allowing it to act to address any harm (or potential harm) being caused to consumers. Evidently, thorough, in-depth MI is key to developing an annual board report that will serve sufficient purpose for the board/governing body to meet its requirement to assess compliance and address harm. Many will have made sufficient progress in the data and MI they have collated over the course of their implementation journey, but firms should now be thinking about compiling the collective MI aspects into a board report fit for purpose. Remember, annual board reports and any actions on the back of each annual report need to be documented and retained for evidence. The FCA has previously stated that such evidence should be readily available, if the regulator feels the need to request it.