In today’s bulletin:
- General update
- Spotting risk earlier by tracking consumer credit journeys
- Fair Value & Customer Understanding Frameworks
- ICO Complaint Handling requirements for FCA-regulated firms
- Embracing AI’s transformational impact on consumer complaints – for better or worse
- Collaborations & Appointments
- Events
General Update
The MaPS monthly update from Dan Pybus attached. This month, they focus on the updated Standards, provide a short update on the new MaPS Standards Portal and note the upcoming FCA review. Daniel Kelly is presenting on the SFS and new innovations at the Affordability Summit.
Link: https://events.ro-ar.com/AffordabilitySummit-UK2026
Affordability Summit – 14/4/2026 in Manchester
Good catching up with Gareth McNab of UK Finance ahead of the Affordability Summit next Tuesday, where Mark Buckley from the CSA is also attending. Our thanks to lead sponsor Paylink and the other sponsors and speakers. We are at over 90 attendees now, including representation from the debt management and personal insolvency sector.
We have touched on a few topical items today that feature affordability.
Talking about money isn’t easy
For a lot of customers, being asked to break down their income and spending can feel uncomfortable, sometimes even overwhelming. And yet, that’s exactly what we ask them to do during affordability checks.
The challenge here isn’t just collecting the right information. It’s how we ask for it, and whether people feel able to answer honestly.
At Paylink, they think about this a lot when designing their affordability journeys, making sure it’s continually improving to make customers feel at ease throughout the process.
We are pleased to have Paylink as lead sponsor, speaker and panelist at the Affordability Summit next Tuesday.
Approving a credit application in under one second and delivering better consumer outcomes – how is that even possible?
A post by Sam Manning at Hope Macy who are speaking and sponsoring the event on 14/4. He will explain how Hope Macy has built a straight‑through affordability process, embedded within their Slick lending platform, capable of assessing a credit application in <1 second, while keeping affordability and customer vulnerability at the heart of every decision.
Their AI Assistants support high‑speed decisioning by ensuring faithful adherence to underwriting policies and FCA regulations, helping reduce friction, making no mistakes, and without compromising consumer protection.
They recently moved past the £400m processing target for unsecured lending on their tech platform. They are now entering the next stage of their journey to reach for the £1 billion mark.
He is looking forward to learning from others across the industry.
Affordability Starts with Insight: Why Utilities Must Truly Know Their Customers in 2026
Interesting Blog by Chloe Charles at Arum Global, who are speaking and sponsoring at the Affordability Summit on 14 April 2026. Carlos is speaking.
“Across the UK’s utility sectors, affordability is fast becoming the defining challenge of 2026. Energy debt has now reached £5.5 billion, water companies are preparing for another year of above inflation bill increases, with 2.5m households already receiving some form of financial support. Broadband, mobile, and council tax rises arriving in April 2026 will compound the pressure further.”
Utilities that lead on affordability in 2026 will be those that:
- invest in data quality & governance
- strengthen affordability assessments
- build proactive vulnerability identification models
- improve cross utility data sharing where permitted
- train frontline teams to recognise and record vulnerability
- ensure systems can deliver regulatory schemes at scale
Bank of England warns of 2008-style financial crash as Iran conflict decimates British economy
“The conflict in the Middle East has resulted in a substantial negative supply shock to the global economy.”
Bank of England Governor Andrew Bailey has warned that the conflict in Iran could trigger a financial crisis similar to the 2008 meltdown. He said turmoil in the $3 trillion private credit sector, equivalent to around £2.2 trillion, could spread across the global economy. He was speaking on Thursday in his role as Financial Stability Board chairman, where he said Britain is already facing an energy shock alongside volatility in debt markets.
Latest data from the Bank of England has found that loan defaults have risen to 6.2% in early 2026, the highest since late 2024 (7.8%), when the UK had seen several hikes in interest rates. Unsecured lending defaults hit 18.6% in Q1 this year, the highest figure since the last quarter of 2023. The ongoing conflict in the Middle East is raising costs, leading to concerns about future defaults. Lenders reported that demand for secured lending for house purchase was unchanged (to the end of February 2026) following the Autumn Budget, but and was expected to increase in Q2. Demand for secured lending for remortgaging increased in Q1 and was also expected to increase in Q2.
There was minimal change regarding consumer demand for unsecured lending, which remained unchanged in Q1 and is expected to remain so in Q2. New figures released by the Finance & Leasing Association (FLA) show that second charge mortgage new business volumes grew by 27% in February 2026.
Link: https://www.credit-connect.co.uk/news/lending-defaults-hits-two-year-high/
Link: https://www.credit-connect.co.uk/news/second-charge-mortgages-hits-highest-level-since-2008/
A further impact from UK Finance is from higher mortgage costs – notably for around 1.8m households that will be refinancing this year.
The ultimate impact on financial stability will depend on the duration, scale and repercussions of the conflict, including whether any additional shocks materialise around the same time.
Chris and I look at the potential impact on inflation and interest rates at the Affordability Summit on 14 April 2026. Domestically, the economic outlook has deteriorated, increasing pressure on UK households and businesses.
“Valuations remain particularly stretched for US technology companies focused on artificial intelligence (AI). Prior to the conflict, increasing debt-financing needs and concerns about whether expected returns on very significant AI-related investments would materialise led to selling pressure, illustrating the risks around these valuations. The conflict could increase these concerns, particularly given the energy-intensive nature of the supply chain for key components and the operation of data centres.”
This is going on in parallel with FCA plans to help people get more financial advice for important investment decisions. These should probably come with a major health warning, where the government is asking the UK public to bail out their stalled growth programme, as well as take out more credit.
There seems to be a dis-connect between some of the rhetoric in the FCA simplification releases versus ‘Big Data’ messaging coming out from other parts of the FCA (see below) where only they have access to the PS24/3 PSD data.
Link: https://www.bankofengland.co.uk/financial-policy-committee-record/2026/april-2026
Link: https://www.ukfinance.org.uk/data-and-research/economic-insight/monthly-economic-review-april-2026
- The total value of assets held by UK Credit Unions fell by 0.08% to £4.91 billion in 2025 Q3
- Credit Union adult membership declined by 0.84% to 2.16m in Q3 2025 – first quarterly fall since Q3 2022
- Total value of net liabilities in arrears continued to grow, increasing by 3.18% to £269.58m in Q3 2025
Link: https://www.bankofengland.co.uk/statistics/credit-union/2025/2025-q3
Spotting risk earlier by tracking consumer credit journeys
Interesting Blog by Alison Walters, Director of Consumer Finance at the FCA. They are using credit‑file data & analytics to track consumers’ credit journeys over time, enabling earlier identification of financial stress and more targeted supervisory action.
The goal is to make regulation evidence‑based and focused on good consumer outcomes. Richer datasets should help widen financial inclusion. It heralds wider use of Product Sales Data (PSD – PS24/3 – Nov 2024). DMCs provide their CCR009 returns later in April 2026.
They are using credit‑file data from a CRA and applying statistical methods to identify which consumers are likely to fall into distress, and when.
🤔 ‘Big Data’ allows pattern detection individual firms can’t see.
No reference to open banking. Traditional metrics (e.g. delinquency, credit scores, payment history) often flag issues after they occur and fail to capture:
- Direction of travel
- Velocity of deterioration
- Persistence (i.e. temporary or sustained)
- Combined signals (e.g. cumulative increase in risk)
Consumers grouped into 5 buckets:
- Distressed (5%) – severe issues (e.g., debt remedy, defaults)
- At Risk (5%) – early warning signs (missed payments, high utilisation, multiple new unsecured accounts)
- Secured Credit Users (≈33%) – mortgage holders with stable behaviour
- Unsecured Credit Users (≈20%) – active unsecured credit users with stable behaviour
- Low Credit Engagement (≈33%) – limited or no formal credit use
The FCA tracks transitions between these states to identify emerging stress.
⚠️ Distress rarely appears suddenly
⚠️ Recovery times varies
⚠️ At‑risk consumers have the shortest expected period of financial stability
⚠️ Recent missed payments, multiple new unsecured accounts, and rising credit utilisation accelerate movement into distress
⚠️ Low‑engagement and secured‑credit groups remain stable the longest
All closely aligned with the Consumer Duty and the consumer support and consumer understanding outcomes. Expectations:
☑️ Offer support before arrears occur
☑️ Tailor support to individual circumstances
☑️ Pay particular attention to vulnerable customers
This will include DPC/BNPL in future models. It allows ongoing monitoring of consumer credit journeys to identify risks earlier. Collaboration is promised.
This matters operationally for firms with increased expectations for proactive, tailored support, with more supervisory focus on affordability, vulnerability, and credit journey patterns, not just arrears. Alison is speaking at the Vulnerability Registration Service (VRS) Conference on 7 May 2026 in Nottingham.
Link: https://www.fca.org.uk/news/blogs/spotting-risk-earlier-tracking-consumer-credit-journeys
Interesting post by Nicola Crump at Square 4 Partners around the scale of FCA activity in Q1 2026 into Q2. This is despite “Dear CEO” and Portfolio letters being stopped.
Link: https://www.square4.com/the-fca-isnt-waiting-six-papers-ten-weeks-one-message/
How much collaborations there will be with the impacted sectors remains to be seen ahead of Consumer Duty Board reports in July 2026. The trade bodies don’t get much of a ‘heads up’. It would be useful having another meaningful session at the FCA, much like the one in July 2025.
AI & Data Governance needs to be weaved into this strategic planning agenda along with Operational Resilience, Non-Financial Mis-conduct (NFM), new Redress Schemes & Reporting and the impending DUAA changes around complaint handling policies that don’t align well with DISP.
Fair Value & Customer Understanding Frameworks
Under the Financial Conduct Authority’s (FCA) Consumer Duty, the linkage between fair value assessments (Outcome 2) and customer understanding (Outcome 3) is a core component of the requirement for debt management firms to deliver holistic good outcomes on an ongoing basis throughout the customer journey (e.g. in a DMP).
Blog link below. Please like and/or comment.
Chris and I have collaborated on a more detailed document (attached) for the Compliance and Senior Management folk on the circulation. I hope that you find this helpful ahead of Consumer Duty Board reports in July 2026.
Link: https://www.linkedin.com/pulse/fair-value-customer-understanding-g3gme/
ICO Complaint Handling requirements for FCA-regulated firms
I have posted on this. The ICO published its final guidance on 12 February 2026 requiring all UK firms to handle Data Protection complaints internally before they can be escalated to the regulator. Data controller/processor relationships need thought.
This legal obligation, introduced by the DUAA 2025, comes into force on 19 June 2026. Firms must:
- Facilitate complaints: Clear pathway for individuals to submit DP complaints directly, respecting customer preferences
- Acknowledge within 30 days: The clock starts the day after receipt
- Investigate without “undue delay”: Take steps to investigate on receipt
- Keep complainants informed: Regular updates and expected timeframes
- Communicate the outcome: Include any remedial actions
The DUAA mandates a formal internal data protection complaint process, potentially creating friction with FCA DISP rules regarding response timelines, definition of a “complaint,” and escalation routes. While DISP focuses on prompt financial redress (within 8 weeks), the DUAA imposes a 30-day acknowledgment rule.
POTENTIAL CONFLICT and FRICTION POINTS
🤔 Timeline Mismatch: DUAA requires DP complaints to be acknowledged within 30 days. FCA DISP rules generally require a more rapid acknowledgment and resolution, often aiming for final response within 8 weeks. Reconciling these different regulatory timelines for a single, hybrid complaint (e.g. a data breach causing financial loss) presents operational challenges.
🤔 Definition of Complaint: DUAA treats any data subject dissatisfaction as a formal complaint needing specific handling. This may exceed the FCA’s narrower definition of a complaint under DISP, which is typically centered on the provision of financial services.
🤔 Escalation Paths: DUAA directs unresolved complaints to the ICO. However, financial complaints under DISP are handled by the Financial Ombudsman Service (FOS). A hybrid complaint may require parallel management, with DP issues going to the ICO and financial damage to FOS.
🤔 Investigation Scope: DUAA mandates formal, documented investigations with data subject updates – different from DISP.
DMCs must integrate the formalistic ICO requirements into existing FCA complaints handling procedures without duplicating effort or creating conflicting outcomes.
🤔 Risk of incurring unfair FOS fees?
🤔 One complaint policy on your website?
🤔 Training: Employees need to be able to recognise, record, and escalate data protection complaints immediately, including hybrid cases.
This needs to be aligned with the new FCA Redress Scheme (CP26/9 below) and new complaint reporting requirements from July 2027 under PS25/19.
As a reminder, the FCA published further proposals to strengthen the redress system so consumers get fair and quick compensation when things go wrong, and businesses have more certainty to invest, grow and compete.
The government also published the outcome of its review into the Financial Ombudsman.
This is a significant milestone in the FCA joint work with the Financial Ombudsman Service and the Government to reform the redress system. They are delivering change at ‘speed’ by acting now within their current powers, ahead of the Government’s wider reforms. This includes a new registration stage for complaints, updated dismissal grounds and clearer guidance on the fair and reasonable test. The changes have been designed to:
- help firms address harm early and resolve issues more effectively and proactively
- enable firms to escalate major or emerging redress issues earlier so they can be resolved quickly
- speed up complaint resolution by enabling the Financial Ombudsman to work more efficiently
The FCA encouraged trade bodies to share details with members and among interested networks. This closes on 11 May 2026.
Link: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/
Firms’ customer due diligence (CDD) processes & controls: FCA findings
I have posted on this.
Embracing AI’s transformational impact on consumer complaints
AI is reshaping the financial services world at remarkable speed. The FOS Chief Operating Officer, Marc Harris, looks how these changes are impacting the complaints, questions and experiences consumers bring to them. Many firms have started to see AI used by consumers in expressions of dissatisfaction and complaints. FOS has laid out their AI principles.
“Over the past year, we’ve seen a clear rise in consumers using generative AI to help draft complaints or communicate with us.”
“What’s clear is that maintaining a fair, accessible and trusted redress system in an AI-driven world requires consistent guidance, shared insight and close collaboration with partners across the sector. We welcome the FCA’s focus on this through the Mills Review and look forward to continuing to contribute our evidence, experience and expertise.”
Excessive or uncritical use of generative AI can lead to:
- Needlessly long or unfocused submissions
- Incoherent narratives that obscure rather than clarify
- ‘Hallucinations’ which include fabricated laws, misquoted regulations or invented past decisions
- Erroneous service complaints, that can clog up the service and ultimately mean slower response times for other users.
In a small sample of cases they recently reviewed, up to a third of responses to their initial assessments appeared to have been generated or heavily assisted by AI. While some of these were helpful, others required significant caseworker time simply to verify the accuracy of the content, something that ultimately delays outcomes for everyone.
FOS know firms are seeing similar trends. Long, AI generated complaints containing inaccuracies are beginning to generate unnecessary burden and extend response times. While this is not yet a major operational issue for the sector, it is an emerging risk that warrants coordinated attention.
Complaint policies need to be reviewed more broadly, where these pointers should be useful.
Link: https://www.financial-ombudsman.org.uk/who-we-are/aims-values/ai-principles
Collaborations & Appointments
Lee Healey interview by Chris
A major theme is the balance between human support and digital innovation, including the use of AI to scale customer service while preserving empathy, judgement and inclusion. Overall, institutions can design more humane, effective and resilient support systems for customers facing financial strain.
Lee is speaking at the Affordability Summit on 14 April in the session around income optimisation. He has also posted on the changes in benefits and entitlements. I have attached the summary sheet.
Link: https://www.ro-ar.com/beyond-ai-hype-what-digital-transformation-really-means-2/
Chris also spoke with Cat Divers of National Support Network.
The National Support Network (NSN) is a UK-based social enterprise that provides a digital platform called the Support Hub. We have featured a number of their case studies. They have partnered with CIVEA and the Vulnerability Registration Service (VRS). Cat and Helen have supported a number of the events run by Chris and myself through 2025.
Link: https://www.ro-ar.com/national-support-network/
Policy in Practice at the Affordability Summit with partner Welfare Together
Digital DRA on TV – Watch out alert
From 13th April, the Digital DRA TV campaign goes live for 6 weeks across Sky News, GB News, ITV2, ITV4, True Crime, True Crime Extra, Quest Red, Discovery, DMAX, Comedy Central, Crime & Investigation, GREAT! TV, GREAT! Action, U&ALIBI and U&W.
We will catch up with Dan and Arren on 14 April at the Affordability Summit.
Zinc Group and MEGA.AI
Dougie, Peter, Adam and Zinc Group team collaborated this week, listening to calls, analyzing performance and optimising customer touchpoints.
Focus on:
→ Conversion rate
→ Connection rate
→ Customer satisfaction
Events
LinkedIn Live with MEGA.AI recording from 10/4/2026
A new version of ISO 42001 was published on 31 March 2026. I aim to be fully familiar with this ahead of the AI Governance event at the BSI offices in Milton Keynes on 25 June 2026. Please drop me or Chris an email if you are interested in attending. MEGA.AI is a sponsor. We hope to announce some of the other sponsors and speakers in the coming weeks alongside BSI.
The image below covers many of the points discussed:
The next LinkedIn Live is 11am on 17 April 2026.
The turning point for enforcement – 23 April 2026
I am pleased to be supporting this CIVEA in April 2026. Interesting agenda. I am sure that we will pick up on some of the topics covered at the CIVEA/DEMSA in November 2025 where the ECB presented their expectations on their Vulnerability and Ability to Pay standards. 2026 is a big year for delivery of the standards in conjunction with the debt advice sector.
The theme, “A Turning Point for Enforcement”, will drive discussions as we look ahead to exploring innovative solutions and future strategies in civil enforcement.
Core themes:
- Political and Economic Shifts: How will a new Labour Government’s agenda reshape the landscape of enforcement?
- A New Era of Regulation: We will look ahead to the future of the industry, anticipating the impact of the ECB and new statutory regulation.
- Supporting Our Partners: With the ongoing devolution of councils, we will examine the unique issues faced by local authorities and how our sector can provide effective support.
- Challenges and Opportunities: We will address the evolving landscape of the parking sector and explore new approaches to managing vulnerability across all areas of enforcement.
- Social Value and Procurement: How are these applied in other sectors, and what can we learn?
- Abuse of Enforcement and the ‘Safer Enforcement’ Campaign: A crucial discussion on protecting our profession and the public.
Link: https://civeaconference.org/
VRS conference on 7 May 2026 – Nottingham Forest Football ground
The FCA and the ICO are both keynoting. Opening keynote from Lord Holmes MBE – a technology policy leader and advocate for inclusion and accessibility. John Fairhurst from PayPlan is on the main podium and Emma Gibbons is supporting their exhibition stand.
Chris and I are both running sessions. I am looking forward to having Ofgem, CCW and Gamcare in my session. Really good attendance reported so far by Heidi.
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