An Insight into the Modern World of Enforcement – [FULL INTERVIEW]

In this conversation with Russell Hamblin-Boone, CEO of the Civil Enforcement Association, we discuss some of the innovations that have been reshaping the sector, highlighting significant regulatory changes, the introduction of the Enforcement Conduct Board, and the nuanced approaches to debt collection in a post-pandemic society.

The conversation sheds light on the complexities of modern enforcement practices, the impact of technology, and the evolving relationship between enforcement agencies, debtors, and the broader community.

Find out more about CIVEA -> Here.

Key Points

  1. The Taking Control of Goods regulations, crucial for defining enforcement firm operations, are now a decade old and not fully reflective of current practices.
  2. Voluntary industry reforms have led to a new code of practice, complaint adjudication improvements, and the establishment of the Enforcement Conduct Board.
  3. Post-pandemic, enforcement firms are expected to navigate a balance between strict regulation adherence and flexible, principled responses to individual debtor circumstances.
  4. Recent government reviews of enforcement and debt collection have been perceived as inadequate by some in the industry, highlighting the need for more substantive changes.
  5. The use of body-worn cameras by enforcement agents has become mandatory, aimed at improving transparency and accountability.
  6. The pandemic has increased public confrontations and assaults on enforcement agents, reflecting a broader societal trend of declining deference to authority.
  7. Technology’s role in enforcement has expanded, with data analytics and AI offering new avenues for understanding debtor circumstances and improving engagement strategies.
  8. The industry is moving towards a more segmented approach to debt collection, tailoring strategies to the specific needs and situations of different debtor groups.
  9. Enforcement firms are introducing a “pre-compliance stage” to better assess debtor circumstances before initiating collection actions.
  10. The enforcement sector is grappling with a backlog of debt, exacerbated by the pandemic and court delays, necessitating innovative approaches to debt resolution.
  11. The cost of enforcement activities is covered by fees added to the debtor’s total owed, incentivizing early repayment to avoid additional charges.
  12. The enforcement industry is increasingly leveraging fintech solutions and behavioral science to enhance engagement and payment collection from debtors.

Key Statistics

  • Council tax cases represent about 28% of civil enforcement work.
  • Penalty charge notices (traffic and parking offences) account for 60% of civil enforcement activities.
  • The overall collection rate in the enforcement sector is around 20%, with variations depending on demographics and other factors.
  • There are approximately £5.5 billion in uncollected council tax debts, underscoring the scale of the enforcement challenge.

Key Takeaways

  • The enforcement industry is undergoing significant reform, driven by both regulatory changes and voluntary industry initiatives.
  • Technological advancements, including the use of AI and data analytics, are transforming enforcement strategies.
  • Body-worn cameras are now a standard requirement for enforcement agents, enhancing transparency and reducing frivolous complaints.
  • The industry faces the challenge of adapting to a post-pandemic landscape, marked by increased public aggression and a shift in societal norms.
  • Enforcement firms are developing more nuanced, individualized approaches to debt collection, recognizing the diverse circumstances of debtors.
  • The sector is grappling with a significant backlog of cases, necessitating innovative solutions to improve efficiency and effectiveness.
  • There’s a critical need for clearer government policy and support to address the evolving challenges in debt enforcement and collection.
  • The enforcement industry’s reputation is improving among those who engage directly with it, but stereotypes and misconceptions remain a challenge.
  • The cost of living crisis is introducing new segments of debtors into the enforcement process, requiring sensitive and adaptable collection strategies.
  • Public contracts in the enforcement sector are highly competitive, with firms judged on both collection rates and customer experience metrics.
  • The pandemic has accelerated the integration of fintech and behavioral science into enforcement practices, aiming to increase engagement and collection rates.
  • The enforcement sector’s future will likely involve further integration of technology and data-driven strategies to meet the complex needs of both creditors and debtors.
Interview Transcript

Hi, everyone, I’m here with Russell Hamlin Boone. He’s the CEO of the CIVEA, which is the Civil Law Enforcement Association. Russell, thanks very much for joining me. And you’re in charge of enforcement in England and Wales right. Now. It’s correct. It’s good to be here. I think to start off, I wanted to chat just a little bit about what are some of the latest developments in the enforcement world? In terms of what it what are you seeing these days particularly come out since the pandemic, I think more than anything else, we’ve had much had a big impact. It’s actually 10 years since the taking control of goods regulations came into force. And they’re the regulations that

effectively used to define and measure the work of enforcement firms and enforcement agents. They were drafted 10 years ago, they don’t really reflect modern enforcement practices. And with voluntarily, the industry has taken on a reform programme for which the regulations were in head to say they were the catalyst for the industry to get better. And that reformers included things like a new independently monitored code of practice. We established an independent panel to oversee complaints adjudication and the audit reports that firms get against the code. And then most recently, the biggest development and evolution in the industry has been the establishment of the enforcement conduct board as an independent oversight body, which was launched a couple of years ago and is now starting to move into action and implement some of his plans. And we were big supporters of that being done in the way that it’s been done in collaboration with the DEP device sector. Because we found that there are, there needs to be a more independent voice that looks at the industry and speaks for it based on evidence.

Inevitably, the trade association is going to say one thing, that that advice sector We’re campaigning for changes are going to say another thing. But I think the interesting thing for the industry is that while we are regulated under Ministry of Justice regulations, we’re now in a situation where enforcement firms are working to detailed rules based regulation, which are very prescriptive, but at the same time post pandemic are expected to respond flexibly to individual circumstances as if the regulations were principle based. And that creates a kind of tension where public bodies and firms contracted to them have legal duties to recover that.

But firms are also under pressure to exercise. I think what in the commercial sector you call forbearance, particularly for vulnerable people. And it puts a spin on what’s reasonable and fair, where it has to apply to the taxpayer and to the person in debt.

There are new rules that came out. Was it last week? I think it was the government coming back in terms of reviewing around some of the rules around the enforcement, but also debt collection within the local authority sector? And what was your kind of take on those? Because it felt like the government response, it didn’t seem to fully endorse all the recommendations that came out? Yeah, I think there are two things to say there. First of all, it was looking at council tax collection. And I think, given the sort of political environment, that sort of, we’re in with the sort of uncertainty where maybe No, no single party has that much political strength ahead of the election and things like that. And certainly the governing party at the moment doesn’t seem to have. So there was an opportunity to, perhaps to say, look, let’s just commit political suicide reform the whole council tax system, we haven’t really, we haven’t reevaluated properties for 30 years, it’s really probably not reflective of people’s circumstances. So let’s find a new way of doing it, even though it’s going to be massively unpopular. But as the government, we’re probably going to be out of office next time and maybe come back in five years time. Who knows. And those are rare opportunities that are going to come along, when politically, you could say, let’s just do something that’s for the good of the country, even though it’s not good for our party. And that was a missed opportunity. So instead, you have the select committee, come up with some sort of lightweight kind of recommendations around some stuff around sort of data sharing and collections activity and trying to build some sort of affordability assessment into council tax payments. And of course, it’s all kind of tinkering around the edges. A lot of it is already being done because we’ve had 30 years of having a go at this stuff and tweaking it and trying new things and within the framework that’s pretty rigid. And so Unsurprisingly, the government has

they’d come back and said yet we’re when we’ve got data sharing pilots. We can’t not, we can’t put so much forbearance into it that more and more people are not paying council tax because we need council tax, especially post pandemic councils have got holes in their budgets. And so we felt that it was a very politically driven inquiry that was never really going to come up with any substantive regulations that the government could could run with.

It was interesting, it seemed like that what they came back with didn’t really seem to change much what the recommendations were from nothing’s from the select committee. So it was almost felt like it was almost like it stopped in my tracks a certain extent rather than being economic progress to one way or the other, if anything. Yeah, there is some progress,

potentially, in Wales, where they’ve had two consultations already on council tax reform. And they’ve got another consultation this year on

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on council tax reduction schemes, where they’re trying to look at are there different ways of banding and trying to do things individually within in the country that sort of they can do on a national level, quite simply, and perhaps it could be pioneering. And perhaps it could pave the way for changes in England. But it’s been driven by a concern that there’s a problem with the way council tax is collected. And this is one of the challenges that you’ve got here is that

the easy target is the way it’s collected. And enforcement agents or as bailiffs as people call them colloquially, but it ignores the fact that council tax cases accounted for about 28% of civil enforcement work.

60% is penalty charge notices sort of traffic and parking offences. But the it’s there’s always a focus on how the council tax is collected, rather than further upstream as to where the problems might lie, in terms of who’s having to pay and how they’re having to pay and what they’re having to pay.

It’s almost like sometimes it’s almost like feels like they wait too late. And then it goes out to enforcement. And they’re, and they’re actually cleaning up the issues that are probably further upstream to certain extent as much as anything. But obviously, there’s the media around that, which is it does. Do you think that

taking a step back, you talked about what’s changed over the last year? And what some of the things where you think it has changed, and some of the issues which has gone away to a certain extent?

Yeah, I think that

we’ve been, we’ve voluntarily introduced the enforcement conduct board. So we’ve said, Look, we’re open to scrutiny, provided it’s independent, and provided it’s evidence based, we didn’t want to get subsumed by say, the Financial Conduct Authority and just be a sort of tiny part of a big organisation that didn’t really understand us. And we needed to have some sort of oversight of a body that was specialists to our work, because we

people will often have strong opinions about the work of enforcement, but they also have a very low level of knowledge about what we do.

And so the industry itself has been transformed, particularly by the use of technology.

All of the things that you see in a

commercial debt collection agency in terms of the use of technology, the use of credit reference agencies, all of that stuff is standard practice in the enforcement sector.

We have the same challenges of trying to communicate with people engaging people to start talking about their debts and find ways of resolving their debt, we have the same challenges even greater challenges, in terms of understanding people’s circumstances. It’s often said, the DCA is held up as a sort of an exemplar. But it doesn’t acknowledge the fact that if you’re an enforcement firm, you get an order from the court, and that will give you a name and address. It’ll tell you what the debts for and how much it is, and possibly give you a custom vehicle registration number. And that’s it. And information will be months, possibly even years old.

And that’s your starting point. So you’ve got to, first of all, engage with that individual, and then start to gather as much information about them as you can to understand their circumstances. And that’s incredibly difficult, particularly when it’s people who owed that and maybe don’t want to pay it back. So

it’s often said that enforcement agents use heavy handed or they’re not taking into people into account people’s circumstances or whatever or people complain and say an enforcement agent came and they didn’t realise that my wife suffering from this and I’ve got this and I’ve got, of course we don’t because all we’ve got is a name and address and attract

tracing you down in the first place is a success, we can then listen to what you’ve got to say and try to understand circumstances. And what will happen is that if someone’s identified as vulnerable, and that’s evidenced, then it will go back to the Council for review for council tax, possibly to other authorities that we work for public bodies that we work for, to see whether

the enforcement should actually should continue, or whether it shouldn’t be suspended or stopped altogether. So it’s really quite complex work that involves a number of processes, tracing people, engaging people, then trying to understand how you resolve their debt and all, at the same time making sure that you’re being fair to the taxpayers who are funding this. Yeah, one of the things that definitely strikes, particularly doing one to one kind of visits is just the written richness of the information you get, right. So for example, vulnerability in vulnerable situations, when you actually standing outside someone’s house, you can actually ascertain a lot more information than you would if you’re just on a telephone or you’re looking through a spreadsheet or getting trace kind of information. Is that is that is that fair? In terms of like how you can actually gather the information even feed someone that like we talked about this data sort of sentry kind of world we’re moving into? Is that part of what people are thinking about? Yeah, absolutely. There’s no excuse for no alternative, better alternative than obviously being able to visit someone in their home and understand their circumstances and my shadow the enforcement agents, and I’ve seen how much information you can glean and and use of a union enforcement agents are highly trained, they can make a judgement about whether someone’s to detain them or whether they’re genuine in their circumstances and give you lots of examples and practice I won’t go into now. But but

the value of that I think, is shown by the fact that voluntarily, the industry has introduced a new stage into the enforcement process, which comes for their any visits, that is itself, a visit, something they are offering up to councils is that they will have what they’re calling a pre compliance stage, where before they make any attempt to collect them, but just try and find out the individual circumstances. So that might be visited property, just have a visit not to collect any debt or anything just to understand that individuals circumstances, whether they’re even able to pay that might be through sort of communications campaigns and things of back

to the the first instance becomes, we just need to get a dialogue going with this person. Once we do that, we can then start to discern whether the individual is someone who needs help, is someone able to pay someone not able to pay or somebody for whom enforcement is appropriate, who’s willfully not paying, even though they’re able to

the decision we made by the counsel or we made by the enforcement agent? Yeah, so enforcement firms offering up this additional stage councillors have got huge backlog of historic debt that was building up before the pandemic, because of court delays and things like that has been exacerbated since the pandemic councils offered, sort of people payment holidays, they suspended enforcement action, we voluntarily took our agents off the streets, recognising when we first started understand the dangers of the pandemic and visits. But all of that has to be caught up with somewhere. And that’s where we’re at the stage now is, counsellors are being much more analytical about segmenting different groups of people, which people do, can we focus on? Because we know we there’s net to be collected there at the other end? Which people do we know enough about to know that there’s no way that they’re going to be able to pay this and perhaps we need to think about rights or policies or whatever else it is. So it’s not a blanket approach. And they’re looking to enforcement firms to use their expertise to help them work out the best way of approaching individuals circumstances and trying to get through this backlog.

My body cameras has been in the news recently, don’t you see them now? Even in things like the supermarket I noticed the other day, right. And they’re coming up and they’re just, they’re so small. How prevalent is that now in, particularly the enforcement industry? Continue using that and what are some of the complexities of that kind of introduces really? Yeah, so we voluntarily

mandated the use of enforcement of body worn cameras for all enforcement agents were in in our membership. And then, shortly after that, the Ministry of Justice made it compulsory for anybody

undertaking taping, working under the tighten control of goods regulations to

have to use body worn video cameras, and we were promised that they were being guided

So on top of that, to offer some consistency as to how they used, and we’ve worked with government sharing all of the kind of the individual company policies, but we haven’t had any sort of consistent guidance yet. But we haven’t had too much of an issue with data protection or privacy issues. We’ve got robust compliance procedures in place, anyone can make a subject access request to see the data that’s held on them the film footage that’s held for a limited time. And it also enforcement agents to be subject to quality control on the doorstep, because enforcement firms can

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do random checks on video footage, which they do, it means that we can review when there are complaints, we can easily review the evidence and see what happens in the in the truth of things. And it’s really important because enforcement agents representing public bodies, whether it’s local authority, or hmcts, or whatever, so they have to maintain the highest standards, especially when they’re engaging with the public. body worn video allows firms to be able to provide assurances to the central and local government departments that they’re working on behalf of those standards are being maintained. I do think that body worn video is a bit of a double edged sword though, because while it reduces spurious complaints, although you will get some people still claiming that the camera lies when they actually see how they behaved in camera.

It also presents a target for an agent if they’re assaulted. The first thing that I’m going to say that grabs for is the camera.

And I think that, on balance, enforcement agents appreciate the extra layer of protection that body worn video provides. If you’re the man or woman knocking on someone’s door, and you’re alone, and that person takes issue with your request for you to pay your debt. It’s a potentially volatile situation. Most people are fine, and they understand that these are people doing their job and that they owe the debt and everything else. But what we have seen since the pandemic is a rise in abuse and assaults, along with the retail sector and transport and hospitality sectors, is what I call the fracturing of the social contract, which has happened since the pandemic where people have given themselves permission to be less compliance to challenge authority, sometimes quite sort of violently, and stand up for what they believe are their own personal rights, which means that they the rules don’t apply to them in the same way. I don’t know what the reasons for that is. But something has happened in the sort of sneaky of society, which means that we can do things we can break rules, we can apply rules, in a way that suits our own.

Our own purposes, which is a worrying trend. So is that something you’ve seen definitely from almost like before the pandemic to now is it so the rule of compliance to the rules or good behaviour? In some ways as deteriorated? Yeah, there was always an element of risk involved in the type of work the enforcement agents do and that somebody won’t video as as helped that in many respects, but yeah, I mean, definitely since the pandemic, we work closely with the British Parking Association and what are called civil enforcement officers. Now we will know as parking attendants or traffic wardens, they’re seeing that arising this, as you said, even in supermarkets, people wearing body worn video, in our local cinema in the foyer, the pick and mix is a sign saying, Please don’t abuse our staff for the pick and mix.

You know, so? Yeah, I think there’s something bigger going on. And we have to respond to that. And firms are doing that as well. And one of the ways of doing that I think we’re seeing is we’re looking at different forms for recruiting enforcement agents is much more about communications. So some of the best enforcement agents have worked in sort of sales and retail because they’re good at building a rapport with people, as well as in other circumstances, recruiting from the police service or the prison service or whatever, people who’ve got that kind of conflict management background and you have to have that mix. Now. certain individuals are better at certain collecting certain types of debt council tax, which there’s an overemphasis on is the most sensitive, because generally, if you’re in debt with your council tax, it’s through other circumstances is not usually something you’ve done yourself. Not usually whereas penalty charge notices or court fines or something. You’ve deliberately done something that has meant you’ve broken the law and you’ve got a penalty for

So that’s quite interesting in terms of like maybe a different segmentation in terms of also skills of the enforcement agent as well. So you’ve meant your book, depending on the type of debt, maybe for the type of work or the type of interaction you need to have with people who you’re going to visit. Yeah, and it already happens forcement officers do a different type of work. You’ve got bailiffs doing evictions, and moving traveller sites and all that type of things. And they’ve got a different skill set. So the guys who are knocking on people’s doors saying, Look, unfortunately, you haven’t paid your council tax, and it’s a priority debt. And I’ve got to find a way of resolving that with you. Yeah.

I think that the body cameras kind of piece is interesting in terms of how does that in terms of the media noise around the industry is very different necessarily, from what actually happens on on doorsteps or actually happens in person, right? And you’re just like, kind of trying to cut that down in terms of what the reality is, versus what the narrative that everyone likes to talk about. And we see this interest wide, more widely in collections as well, which is, the reality on the floor is actually a lot different from what people think it is, right? I mean, you’re just starting to come close together, and body cameras help with that. But how much of a gap? Do you think we still got around it, particularly enforcement industry? Yeah, I think it’s, it’s just a gap in understanding, there’s definitely a gap. And then however much you present, the reality of what the work is, people have already got the preconceived opinion, and are therefore trying to find evidence that fits their preconceived opinion, as opposed to new information that you’re telling them. We did a drop in session for MPs in Parliament last year, and just invited MPs and their staff to come along and talk to us meet the bailiff type of thing. And very few of them came along with any case studies or constituency issues, they all came along with an opinion about what they thought we did, and left with a completely different opinion, understanding that the kind of the logic of why would you act heavy handedly or aggressively when your contract is dependent on your conduct and the standards of your service is you’re not just measured on payments that you’re collecting for the council, for the courts, or whatever, you’re also measured on how few complaints there are, and what your customer experience is, and the standards of conduct. All of those are metrics that go towards assessing whether you get your contract renewed. And these are public contracts, which are really valuable and highly, highly competitive. So you’ve got to make sure that your business is of the highest standard, because you can bet your life though, in a small industry, there’s a competitor who will step in and say we can do that. If they’ve made a mistake, we won’t make that mistake, we’ve got no loyalty, we’ll just get someone else to do do the job. So it doesn’t make sense to suggest that there are enforcement, there’s bad in everything. I’m not. I’m not an apologist in any way. But I will defend the majority of enforcement agents for doing their job in the best way possible. In the most difficult circumstances, as I said, for a number of reasons, especially since since the pandemic, and we’ll continue to push back against the stereotype that people keep trying to pigeonhole us into. Do you think it’s improving? Or do you still think we’ve got a long way to go? In terms of like stereotypes? Yeah. If I say if I don’t say it’s improving, then that’s not good reflection on me, is it?

But I think there is this challenge of people who are open to it, have their, their their minds broadened. When they start to understand the breadth of the work, the scale of the work, we work closely, the ministry of justice officials get it the enforcement conduct board, newly appointed staff have been out shadowing enforcement agents, they’ve been visiting firms, they’ve been listening in the contact centres, so they’re starting to get it, they start to understand it. It’s not necessarily

so easy viewing or easy listening is difficult work. And it’s not necessarily light touch and soft and fluffy as everybody would like it to be. But if it wasn’t it, then you wouldn’t be getting 40% of collection before a visit. You wouldn’t get overall collection rates are around about 20%, sometimes higher, depending on the demographics of collecting really hard to collect debt. That’s five and a half billion pounds worth of uncollected council tax alone, which will go a long way to sorting some of the Public Service challenges that we can come on. I think that

where people are directly engaged with us, you talk to any of the counsellors that you’ve talked to any of the sort of the technical technology suppliers, they’ll all say, You know what this industry is a good industry. It’s a robust industry and it’s doing

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In a good job, those people who are on the periphery, and particularly those who see things through the prism of people with problems, will say it’s outrageous. But we’ll get back to body worn video, look at the body worn video, look at the low number of complaints.

Chain change, particularly with things like the cost of living example, or the energy price increase, it seems like we’ve got probably maybe a slightly increasing a new segment of people going into arrears, and they’d fall falling down, is that changing the dynamics at all? Because you’re coming across maybe new people who haven’t seen it before, versus people who maybe come across the industry before that changing the dynamics, do you think I think that’s a really good point, and the enforcement firms will certainly we are now starting to see people who aren’t regularly in debt, perhaps have never been in debt, have said

that for young people were on lower incomes and things. And the industry has to adapt to those people. Because if those people have got themselves so far down the line, through all of the sort of attempts, in essence, counselling tears, they’ve missed all of the kind of reminders they missed all of the efforts of the local local authorities attempt to help them sort this out.

To the point that the council is now taking them to court and they’re in the enforcement process is quite scary when you get that notice enforcement that says the council is taking you to court and was now instructed us as bailiffs enforcement agents to come in and recover your that will take control of goods, because that’s the bottom line. That’s the law.

But at the same time, we have to recognise that it might just be people who don’t know how the system works, and they don’t realise that it’s ended up like this. And you have to to take each case on its merits and enforcement firms exercise what is the equivalent of forbearance, particularly around council tax, again, we keep talking about council tax, there’s lots of other deficits collected from the government.

And like, child support payments, for example, there’s a good example of doing good for society.

But yeah, I think that there has been a firm’s have adopted, they’re, they’re adapted their approach to, to individual circumstances. And while it’s still enforcement, according to the regulations, there’s a whole new sort of a number of layers on top of that, in terms of responsible

you’re also at the point where if someone’s been ignoring something, or they’ve been sticking their head in the sand around addressing something for that long, maybe procrastinate about taking action, you can’t change the past, but what you can do is standing there in front of them now about their, their penalty notes, or whatever it is, look, we can help you going forward, we can’t change what’s happened before. But in the customers mind, they’re probably angry about all the stuff done before and they haven’t done it and all that, and you’re having to deal with all of those things. But all you can do is address the best you can with what’s going forward and like help them out of the situation. Yeah. And, you know, it isn’t necessarily

enforcing is a possible thing, particularly penalty charge notices, if your car gets clamped, and then someone knocks on the door and says, Look, I’ve tracked your car, because you still haven’t paid your

whatever you find is for your parking fine. And I’m not going to release it until you pay your parking fine, or I’m going to take your car away.

That feels heavy handed. But actually, what’s the alternative go around begging people to please pay up creating more and more cost for for local authorities or for the taxpayer. And I suppose that’s another point to make is that the cost of enforcement, the cost of enforcement agent is at no cost to the taxpayer or to the local authority. The fees for the work that we do are fixed by government and added to the debt that the person owes. So effectively, they pay for the work of the enforcement agent. And one of the reasons for doing that is to try to get them to pay early so they don’t incur those costs.

Because they’ve sorted the debt before it gets to that stage.

Very good. And so why do you think the industry goes from here? Do you think so? I know we touched a little bit on data. What but what what do you think’s next there? How do you see it changing over the next like 510 years? Yeah, I think data is probably the key. We’ve got our conference in April, where data is a big part of that. And lots of sectors will do the same as well. But I think it’s where you can combine the data that is held in the public sector with the way that data can be used in the private sector. And we’re already seeing pilots where

government departments on a DWP are sharing their data with local councils, local councils can understand a bit more about people’s circumstances, the benefits they’re on and maybe adapt their collection responses accordingly. But I think where you bring AI into


have an equation where you’ve got a lot of data and AI can help you find better ways of using that data, whether it’s, as I said, about segmenting individuals and into groups and tailoring your communications. In the best way, we do a lot of work using behavioural science and trying to understand what are the best ways to prompt responses from people, perhaps me, I can be a part of that, as we go forward. I think ultimately, the fundamental process of

enforcement agents visiting a property on the doorstep, collecting data on behalf of local authorities and central government is not going to change. And the regulations will probably still be quite prescriptive about what that process involves. But there’ll be a whole lot of flexibility around how firms compete to do that, and convince councils that they can do it in the best way possible. And we’re already seeing already seeing the adoption of AI talked about behavioural science with the use of tech firms, they’ve embraced FinTech on a huge scale, to look at the voice messaging and the type of language that you’re using all of those type of things, to get over this issue of get someone to engage, once you’ve got someone to engage, then you can start to collect all the information about them that you don’t have at the start.

I love this idea of almost like the I don’t even call it right, that was like the pre enforcement visit just to gather information around situation I love that idea. Then it’s also interesting around segmentation is no matter where you scratch the surface in terms of segmentation, you can always segment more, and there’s different types of visits probably for different types of debt, different types of situations. And it just allows you to probably get to get engagement quicker, really, which is really what you’re trying to do isn’t either to solve the situation or to enforce artists. Yeah, absolutely. Because the reality is, the counsellors can’t, they don’t they’re not resourced, to cope, to do the sorts of forbearance that most people would want or a campaigning for all the debt collection agencies are able to do perhaps, and so enforcement agents are picking up the slack. If it was an ideal world, enforcement agents would only get cases that were appropriate for enforcement. And therefore, the enforcement methods would result in debts being paid by people who needed to be pursued by enforcement agents. That isn’t, and we would have less cases passed to us, but they would all be quality cases that you’d all be out you could make a living from. Instead, we have to, for want of a better term, sort the wheat from the chaff.

And the chaff is all all the work you put into it, but you’re going to get no return. And then amongst those, you’re going to get a few nuggets, where it’s actually quality work, that you’re going to be able to make getting revenue from

the reality of it, because we have such huge amounts of problem trying to achieve that. Yeah. I mean, as always, it’s like, you drill into these things. And it’s a fact it’s fascinating why just as you more you get into it, the more you could like you can see the layers of how everything how everything lays out. And as you as you said, I think obviously the reality of what’s going on, it’s very different from what people might perceive as well. So I appreciate you, you taking the time to explain that to us, and also where it’s going as well. The whole industry is going as well. So, Russell, thanks very much. You’re very welcome.


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