Our Views

Call for Input on mass redress – an opportunity for change

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Last week we submitted our response to the Call for Input on modernising the redress system. We took this as an opportunity to raise a couple of wider key topics that we were keen to include around the complaints process. One of these is dialogue with the industry around complaints, to improve outcomes for all concerned - firms, the Ombudsman, and ultimately, the consumer. While we believe there are some tangible changes that can be made to the process (which we raise within our submission) there is a need for a more significant change within the FOS, and how it interacts with...

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The importance of smaller lenders

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The news that Santander may leave the UK market has grabbed the headlines. There has been, and we are sure there will continue to be, a lot of discussion about the regulatory burden. The costs mentioned are significant, often more like telephone numbers. The risk is that we focus on those big numbers and the big brands. However, elsewhere, some lenders face burdens that are certainly smaller numbers but can significantly impact that firm. Last year, firms moved to implement the Consumer Duty, introducing new systems and structures. Over recent months, we have seen movement on new data systems required by the...

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An update on motor finance

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As many of you will know, the motor finance world was hit hard in October with the Court of Appeal judgment in the Johnson v FirstRand Bank Limited, Wrench v FirstRand Bank Limited and Hopcraft v Close Brothers cases. The Court of Appeal decided it was unlawful for motor finance brokers to receive a commission from the lender providing motor finance without getting the customer’s informed consent to the payment. This decision surprised many because this case marks a significant shift in how Courts view lenders' duties toward consumers in cases involving commission payments. Firms were tasked with making changes to their processes very...

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Movement on access to credit

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Access to credit has always been central to the work of the CCTA since it was founded over 130 years ago. We have a long-standing project to protect access to responsible credit for customers that often struggle to borrow elsewhere. In recent months, we have seen a greater interest in access to credit and financial inclusion from a range of external stakeholders which as been encouraging. Firstly, we have seen this from the new Labour Government. Prior to the announcement of the General Election, the Labour Party outlined its commitment to a National Financial Inclusion Strategy, should it gain power. This was...

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CCTA Annual Conference 2024

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Last week we held our annual conference at the Radisson Blu, Manchester airport. In keeping with recent tradition, we held our member dinner the night before the conference. Our dinner provided the opportunity for attendees to catch up with colleagues from across the sector and discuss relevant issues in a relaxed setting. Conference kicked off the next morning with our Chair, Mark Fiander welcoming delegates to this year’s event. Jason Wassell, CEO, then provided an update on the work of the association and covered some of the topics that would be discussed during the day. We also got a presentation on our...

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FCA keeps a firm grip on the oversight of Appointed Representatives

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Last week the FCA published the findings of its review of how principal firms are meeting its enhanced appointed representative rules, introduced in December 2022. As a reminder, an appointed representative (AR) is a firm that undertakes regulated activities and acts as an agent for a firm directly authorised by the FCA. This firm is known as the appointed representative’s “principal” firm. The FCA’s review involved a telephone survey with 251 principals and in-depth assessments of documentation from 23 firms and they are keen to share their findings. The current rules state that principal firms must oversee their ARs effectively and are responsible...

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Reducing the burden

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The end of July saw the first anniversary of the implementation of the FCA’s Consumer Duty. This meant vast amounts of work undertaken by regulated firms to prepare, looking to embed the Duty in every stage of the customer journey.  We have supported CCTA members through this process, but it is no means finished, as we know this will be a continual process, especially as requirements for closed products and the Annual Board Report have now come into force too. There is no doubt that the introduction of the Duty has meant extra regulatory requirements which come at a cost. These...

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Consumer Duty – one year on

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It has now been one year since the Consumer Duty came into force for new and existing financial products and services. We are sure that firms will agree; it has been quite a journey so far! The implementation of the Duty has been a somewhat phased approach. The financial services industry had deadlines in relation to approved implementation plans and information exchange requirements. We are now at the stage of the final, hard deadline set for firms under the Duty, that deadline being Annual Board Reports and closed products and services. Over the last year, firms have been living and breathing the...

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What’s happening in the motor finance market?

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After a mortgage, the purchase of a vehicle is often the second largest expense within a household, which is why a range of motor finance options have developed over the years to assist families in making this purchase. The CCTA membership includes motor finance firms of different sizes with various specialisms across the sector. With motor finance being such a large financial services sector, the Financial Conduct Authority (FCA) has carried out various pieces of work into the sector over the years. In 2021, the FCA banned what are referred to as discretionary commission arrangements (DCAs). This removed the incentive for brokers...

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