DEMSA Saturday update: ISO 22458 / Online Safety Bill / Vulnerability Updates / Digital Collections / Events…

General update

Another week dominated by events in Ukraine and the wider impacts of the war and sanctions. Chris Warburton provided a fairly grounded article on this earlier in the week and the potential impact on collections and debt management. I am also hoping that Chris can discuss the survey around engagement methods in collections when the data is all collated.



UK Finance has published data & research (attached) on household finances. This quarterly commentary covers aspects of household finance (mortgages, credit cards, loans, overdrafts and deposits) in the UK. Trends covering all UK card issuers highlight personal card spending and repayment behaviour, while other unsecured borrowing on overdrafts and through personal loans identifies trends in consumers’ borrowing appetite.


The FCA is apparently looking at ways of encouraging firms to lend to the most vulnerable borrowers after the implosion of the high-cost credit industry that the regulator helped to bring about. This seems to come off the back of the presentation by Nisha Arora in October 2021 where she said that this review included looking at “what may be standing in the way of firms lending” to more vulnerable borrowers. FCA intervention would seem to be one of the obstacles. Quote:

“We’re also talking to firms and individuals [with] an interest in this issue to better understand what the supply of credit to these customers could look like in the months and years to come and whether we could act to reduce any barriers to the future affordable and sustainable supply of credit to customers who have few borrowing options.”

I have previously covered news from Morses Club. They will become U Money and will list its shares under that name on Aim, the junior stock market. The doorstep lending business will continue to be called Morses, while the digital division will be called Shelby Finance and will use two existing brands, Dot Dot Loans and U Account, a current account.

The BBC featured some analysis by the Resolution Foundation on the impact of the cost-of-living increases. UK households will see the largest fall in living standards in nearly 50 years with the cost-of-living set to increase further due to rising energy prices, according to a report by their report. Most working age benefits and the state pension are due to rise by 3.1% in April 2022 when inflation could be well over 8%. For the debt advice sector, it is predicting the lag from the changes taking effect and someone deciding to engage in a debt advice session. As we have featured many times before from debt advice provider feedback, this can take 9 months or longer. Credit lines may be increased in the interim for those not already in a debt remedy.  


I have now had several discussions with the IPA around how the IVA Protocol may be reviewed to provide more than 15% flexibility during the lifetime of an IVA. This is important for pre-existing IVAs (notably those originating from 2016 onwards) and newly proposed IVAs. Rising costs need to be factored into the future resilience of informal and formal debt solutions. The IPA, like DEMSA, has been looking into proposals for Statutory Debt Repayment Plans (SDRPs) and the impact in May 2024 on pre-existing DMPs and the options available for new customers requiring a debt remedy. We are still trying to second guess what may happen with the ‘Debt Packager’ final policy statement coming out of CP21/30.

The government’s Economic Crime Bill, aimed at tackling money laundering through the UK, passed the House of Commons unopposed during the week.

The legislation will:

  • create a register of overseas ownership of UK land and property – with punishments for withholding details
  • overhaul Unexplained Wealth Orders
  • make it easier to prosecute anyone involved in sanctions-busting


Registry Trust (RTL) has appointed Polly Mackenzie, CEO of think tank Demos, as a Non-Executive Director. She is former Founding Director of the Money & Mental Health Policy Institute and Director of Policy Innovation at 10 Downing Street. Chair, Mick McAteer, has stated that the RTL mission is to use public data on monetary judgments for the public good. Lex Jones, CEO, has also recently responded to the Centre for Social Justice call for evidence on financial education. This was in response to figures showing that 24m people in the UK do not feel comfortable managing their own money day-to-day, and 9 out of 10 UK consumers feel that they are uneducated in terms of personal finance.  

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R3 has launched an insolvency fee guide entitled  ‘Insolvency fees and the cost of regulation – the detail behind the headlines’. The report aims to address popular misconceptions and myths about insolvency fees. It explains how fees are linked to insolvency regulation, that fees can vary widely depending on case size and complexity, and why insolvency practitioners are often not paid in full for their work – work that helps to return money to creditors, tackle fraud and rescue jobs and businesses.


Arum and Just have just announced that Jason Incles will become the new Chair. He previously worked at the TDX Group from 2006 to 2016. He succeeds Jamie Waller who recently retired after serving as Chair for the past 4 years.

FCA vulnerability model – working towards inclusive design – ISO 22458

I have produced a short teaser (attached) on FCA vulnerability model and embedding inclusive design in regulated firm transformation projects to adopt the FCA Consumer Duty by April 2023. I have a provisional meeting with BSI for the first workshop on the ISO 22458 kitemark on 28 April 2022. I am hoping to provide further information during March 2022. I am aware that Kiren and Jo of BSI have been in contact with several of the early adopters.

At many of the events that I have spoken at since September 2021, the panelists have been asked what ‘good look like’ in terms of quality assurance in a digital world and since the latest version of the FCA Consumer Duty was published in December 2021, the question has been extended to ‘What does the new Consumer Duty mean for digital conduct compliance?’.

I am hoping that inclusive design discussions not only cover identifying and tailoring engagement strategies for vulnerable customers, but the wider challenge of monitoring compliance with FCA expectations around the Consumer Duty where regulated firms maintain an accurate record of customer activity in digital channels, as is normal practice with recorded phone calls. Continuously monitoring digital channel activity to track behaviors and spot issues as they arise should be the norm (e.g. a customer struggling with a particular process step or showing signs of a lack of comprehension). This aligns with some of the product & service reviews that need to be completed in the adoption period from July 2022 to April 2023.

If AI/ML is part of the service proposition then it needs to start learning from experience gained during the scaling up process from pilots or proofs-of-concept. Many of the products & services featured at the industry and awards events that I attend strongly promote innovation and the use of AI/ML. We now need to start looking at how this is for the greater good and how this is communicated to consumers as part of a wider financial education agenda, but more specifically embedded in the customer journey to deliver better outcomes.

We now have an ecosystem of regulated firms delivering products & services directly to consumers in vulnerable circumstances and/or with poor financial literacy supported by a range of service providers where the proposition needs to be joined up. Representing these ‘Target Operating Models’ (TOMs) is becoming a more common requirement, not only to regulators, but to wider stakeholder groups that may now embrace the ESG agenda.  

Online Safety Bill

Major law changes to protect people from scam adverts online

The government has made changes to the Online Safety Bill to tackle scams and fraud. StepChange and DEMSA has welcomed the new legal duty added to the Online Safety Bill requiring the largest and most popular social media platforms and search engines to prevent paid-for fraudulent adverts appearing on their services. Social media sites and search engines will be forced to stamp out fraudsters and scammers on their platforms as the government strengthens its pioneering internet safety laws. Ofcom will set out further details on what platforms will need to do to fulfil their new duty in codes of practice. This could include making firms scan for scam adverts before they are uploaded to their systems, measures such as checking the identity of those who wish to publish advertisements, and ensuring financial promotions are only made by firms authorised by the FCA.

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The government is today launching a public consultation on its Online Advertising Programme (OAP). The content and placement of online advertisements is currently overseen by the Advertising Standards Authority (ASA) under a system of self-regulation. But rapid technological developments have transformed the scale and complexity of online advertising leading to an increase in consumer harm. The Online Advertising Programme consultation opened for 12 weeks from 9 March 2022.

As the cost-of-living crisis bites, it is important consumers have trust and confidence in being online by making sure the UK’s rules and regulations keep pace with rapid advances in technology.


ICO on cyber-resilience

The ICO has highlighted 11 practical ways to keep your IT systems safe and secure. Primarily targeted at small firms.

We are finding more affiliates adopting Cyber Essentials at both the entry level and Cyber Essentials Plus. We have recently featured IE Hub, Cerebreon (4th year) and others being accredited or re-accredited for ISO 27001.  

At a more strategic level, NCSC and the Centre for the Protection of National Infrastructure (CPNI) have issued guidance to help UK’s data centres stay secure. This will for the first time have access to tailor-made advice on how to keep the UK’s online assets secure. The new guidance from the NCSC and CPNI helps users and operators of data centres understand and mitigate potential security vulnerabilities.


Link: h – Cerebreon re-accreditation


PayPlan vulnerable client team

Off the back of a few awards at the end of 2021, PayPlan has been promoting their specialist vulnerable client team and their ‘tell us once’ approach. The team is dedicated to supporting ‘particularly vulnerable’ clients, such as those with a terminal illness, mental incapacity or learning disabilities like dyslexia, where they can offer specialist one-to-one support.

They have also confirmed that they have over 9,700 clients who have disclosed a vulnerability to their advisers and 91% of them disclosed this voluntarily, which is encouraging. They have highlighted the important of all their debt advisers being trained in spotting the signs of vulnerabilities. This includes picking up on verbal or written cues given to them during an advice session and asking additional questions to find out a little more. Where consent has been provided, they record vulnerabilities on the case file, so regardless of which adviser contacts you from PayPlan, they’ll be informed of your individual situation and will be able to tailor the conversation appropriately.

Partners include the National Bereavement Service, Age UK, the Trussell Trust, Samaritans, GamCare, National Domestic Abuse Helpline and many others.


Link: – award winners Emma Gibbons and Iona Murray are featured

Digital engagement – planning for the cost-of-living crisis

As part of my research into my presentation on 23/3/2022 at Credit Summit, I came across this Credit Kudos blog on ‘protecting customers as living costs soar’. This build on common themes from recent bulletins around accurate affordability assessments in debt resolution, but also more widely in terms of forecasting the impact of income and expenditure shocks that are often not in the consumer’s control. Credit Kudos has indicated that the impact of rising living costs is not just hitting low-income households, with the median income of this newly ‘non-affordable’ segment being £22,764 per annum. Furthermore, 29.2% of those projected to have less than £250 leftover each month after essentials earn above the UK median.

Definitely worth a read and this builds on some of the points raised by Ken Doherty of Cerebreon last week and the PayLink Solutions/Credit Kudos case study for a Tier-1 bank.  


IE Hub is offering a range of complementary training courses aimed to help front line advisers reach the right outcomes for customers.


Variable recurring payments (VRPs)

I also spotted that NatWest is to begin pilot testing of variable recurring payments (VRP) with its open banking payments product Payit in the first half of 2022, with plans to scale to a commercial product ready by early 2023. From discussions with several DEMSA affiliates it is not clear whether this is a meaningful step forward or not given the reactions to the UK Finance paper on the direction of Open Banking at the end of 2021. The statement says that this is a change to the current Open Banking status quo where third-party providers (TPPs) can only initiate single immediate payments and customers have to authenticate each payment separately.

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VRPs would seem an important next step in our sector in a volatile economy where time-to-pay (TTP) and debt solution payment arrangements need to be flexible and truly adaptable to customer circumstances and ability to pay.



Shaping the future of debt collections – 17/3/2022

DEMSA has registered for the CRS face-to-face event on Thursday 17 March 2022.


FCA – The Future of Financial Services with Data and AI – 22/3/2022

DEMSA has registered for this FCA event on 22/3/2022. This virtual session includes:

  • What regulatory opportunities will be enabled by data in the next few years
  • How their organisations avoid negative outcomes from bias in their data work
  • What data changes they would like to see from the FCA

The discussion is being led by Jessica Rusu, Chief Data, Information and Intelligence Officer at the FCA.


Credit Summit 2022 – Open Banking – DEMSA is speaking on 23/3/2022

I am looking forwarding to speaking in the Credit Strategy ‘Open Banking’ strand of Credit Summit 2022 on the topic of ‘Overcoming the Challenges’ on 23/3/2022. As we see more economic forecasts around the impact of the cost-of-living crisis for consumers and micro-businesses, it is important to look at the role that Open Banking can play that is beneficial to consumers – even in the arrears management and debt resolution space.

We have a small discount available. MALG has been offering a slightly better discount of 15%.


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Motor Finance Round Table – 24/3/2022

Engage Services ESL Limited is sponsoring Motor Finance Round Table event organised by CCR Magazine to be held at The Dominion Theatre in London on 24 March 2022.

Discussion areas will range from Collections Oversight to Optimising Panel Management to Vulnerability and other topical and current matters. There is no cost to attend. If you are interested in attending contact or call him on 07825 901476. I know that John is an avid reader of the DEMSA bulletin from my last F2F with him (albeit at an industry dinner). We are also part of the same group called ‘sons doing Astro Physics’, though his son has actually graduated.

BSI – How Collaboration enables Innovation – 24/3/2022

In this session, hear from experts about the crossovers between collaboration and innovation and how you can use existing skills and processes to enable collaboration to drive innovation, as well as new frameworks and solutions.


Aveni is supporting the Scottish AI Summit on 30/3/2022

This looks like a sell-out from the home page. Joseph Twigg, CEO of Aveni, is supporting the session entitled ‘Nurturing adoption: supporting the growth of early stage AI driven business in Scotland’.


CYBERUK 2022 – 10-11 May 2022

Registration is now open. The UK government’s flagship cyber-security event will be held at the ICC Wales in Newport, marking a return to an in-person event format.


Vulnerability Summit – 21 July 2022

Just advanced notice of this event, which I am sure will be of interest to many on the circulation. It is a full day event.

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ICO call for views: Anonymisation, pseudonymisation and privacy enhancing technologies guidance – Chapter 4

The consultation ends in September 2022, but DEMSA has been covering the Chapters as they are launched. This is Chapter 4. This chapter on ‘Accountability and governance’ explains the governance approach you should take when you anonymise personal data.

The ICO explores the factors you need to consider for ensuring transparency such as using DPIAs to identify and mitigate risks and keeping up to date with technical and legal developments to ensure anonymisation remains effective. The chapter also provides guidance on other relevant legislation you should consider when disclosing anonymous information. These key topics set out in the ICO’s views on how you should approach your accountability and governance obligations when anonymising personal data and they welcome your feedback.


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