DEMSA update: A week in politics / Gov-Debt / DRO update / Insolvency Stats / Training / Consumer Duty / Events

In today’s bulletin

  • General update
  • Gov-Debt review
  • DRO update
  • Insolvency statistics – September 2022
  • Product Development under FCA Consumer Duty (PS22/9), Principle 12 and PRIN 2A
  • VRS Consumer Duty training on 17/10 and 31/10
  • Mixed message report from Amplified Global and StepChange
  • Events

General update

I am not sure if anyone was running a sweepstake around the number of days in office at Number 11, but the answer is 38. We will now deal with the fallout of another U-turn and see what the market reactions are. This political instability really can’t help the overall economic position and potential escalations in the war zone in Ukraine. There have been mixed reactions to the new chancellor, Jeremy Hunt, who has told the BBC that “difficult decisions” lie ahead, warning that some taxes will go up. The cost of government borrowing rose across a range of bonds traded on the financial markets following announcements at the end of the week.

I attended the Gov-Debt event near the Barbican on Tuesday and it was good to see so many familiar faces and a strong turnout from the public sector, both central and local government. Some interesting discussions around whether the Mini-budget and consequent impact would result in major public spending cuts. Russell Hamblin-Boone (CIVEA) touched on this in his final session with Chris Leslie (CSA), Sue Young (HMRC Director of Debt Management) and Debbie Wright (DWP Head of Debt Management).

The MaPS national debt advice awards (Lot1) are in the period of “Standstill”. ‘Talk Money Week’ is coming up between 7-11 November. Talk Money Week 2021 reached over 15m.

His initial priority is protecting consumers in the short term – “what we can do together and what we expect the industry to do, to help customers through the winter”. He welcomed the government’s Energy Price Guarantee and Energy Bills Support Scheme, which will provide much needed relief to millions of consumers and to small businesses.

In April 2022, Ofgem announced 4 market compliance reviews, focused on direct debits, customer service, support for vulnerable customers and those with difficulty paying. Ofgem has now expanded this programme with 3 more assessments focused on suppliers’ financial robustness and risk management.


BSI Digital Trust and NCSC updated guidance

As we continue to feature factors that build consumer trust, BSI has posted that whilst smart and connected home device uptake has increased, 78% of consumers don’t trust smart home technology. 62% fear someone hacking into their ‘smart home’. They can represent a cyber-security threat and this has become a heightened area of focus, notably with more hybrid working. My thanks to Jo Howcroft for bringing this to my attention. This relates to the BSI Kitemark for the Internet of Things (IoT), which features prominently in many tender processes.

I have attached fact sheet and copied Jo on the bulletin. Interesting that the fact sheet has a prominent image of someone with their energy smart meter. Many connected devices are designed to support vulnerable consumers, so this is a ‘hot topic’, especially as we get closer to Winter. We have several infrastructure providers on the circulation. It is also topical around the data sharing debate and the Priority Service Register (PSR) and who has access to it.

Andy Clowes, Head of CX and Strategy at South-East Water, has been promoting the value of being a member of the Collaboration Network. Encouraging more data sharing in the Water and Energy sector has been a common theme for many of us.    

Meanwhile, we have a few early adopters going through the ISO 22458 (consumer vulnerability) stage 1 and stage 2 assessment process. Watch this space.

Meanwhile, the NCSC has provided an update on the updated Cyber Essentials that was published at the start of the year and attempts to ‘debunk’ some of the myths. This may be relevant to many on the circulation. The next update to the requirements standard is due in early 2023, but it will be a much lighter touch than the 2022 update.

NCSC has issued fresh guidance following recent rise in supply chain cyber attacks. Supply chains feature strongly in much of the FCA operational resilience and Consumer Duty material. Supply chain attacks can cause far-reaching and costly disruption, yet the latest government data shows just over one in ten businesses review the risks posed by their immediate suppliers (13%), and the proportion for the wider supply chain is just 7%.




InBest partnerships – Ophelos

Chris Warburton has recently interviewed both Manu (InBest) and Paul Chong (Ophelos). They have announced their collaboration. DEMSA continues to support a wide range of collaborations between specialist providers where these add value to the customer journey. Cerebreon, Elanev, IE Hub, Inicio AI and PayLink Solutions have all recently collaborated with InBest, as have other providers with providers like EntitledTo, IncomeMax and Policy in Practice. The key is the adoption of best practices and ensuring that creditors see the value of enhanced services through API calls from their CRM and arrears management platforms.

This builds on the message that almost 8m households are missing out on £16 billion of unclaimed benefits. Digital debt resolution providers and debt advice providers are looking at ways of helping consumers with low financial resilience, low household income and multi-occupancy properties. MaPS is still consulting on deficit budgets (closes December 2022) and millions of consumers need to plan for 2023 with further energy cost rises, interest rate increases and cost-of-living rising faster than pay rises and benefit increases (another political ‘hot potato’).  



VRS data shows that vulnerable people are being forced to turn to loan sharks amid cost-of-living crisis

Following on from the Stop Loan Shark campaigns, VRS has confirmed that 630,000 vulnerable people used loan sharks in the last year – more than half of the 1.2m adults in the UK who have turned to unscrupulous loan sharks in the last 12 months. We continue to work with the Illegal Money Lending Team (IMLT) to raise awareness and adding this data to the VRS database is key to highlight potential downstream risks where consumers are declined for regulated credit. This came out strongly in the Credit Union event run on 28 September.

Chris Warburton has now published the final survey results, where we featured the Stop Loan Shark campaign. Page 4 relates to alternative sources of funding and vulnerability.


DP22/4: Artificial Intelligence

The FCA, Bank of England and PRA have a close interest in the safe and responsible adoption of AI in financial services. This includes considering how policy and regulation can best support this.

We want to share and gain feedback on our thinking on:

  • the potential benefits and risks related to the use of AI in financial services
  • how the current regulatory framework applies to AI
  • whether additional clarification of existing regulation may be helpful
  • how policy can best support further safe and responsible AI adoption

This is likely to align with the ICO consultation around use of AI as part of UK GDPR reform. This is likely to be applicable to a number of the circulation. The discussion paper (DP) closes on 10 February 2023.


Gov-Debt review – 11/10/2022

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I represented FourNet at this week’s @GovNet event on 11 October and picked up insights from a range of organisational speakers, including Cabinet Office, CIVEA, Crown Commercial Services, DWP, Experian, HMRC, TDX Group and a number of local government providers. The Gov-Debt looked at a number of public/private sector collaborations and how technology is enabling a number of key initiatives. As discussed above, this event took place as government has been looking at whether cuts in public spending may be required to fund the fallout from the mini-budget and wider cost-of-living crisis around rising energy costs, interest rates and inflation. Russell, Bob, Jabeen Kamran (PSFA), Mark Anchen (CAP), Matt Hooper (CCS) and Steve from left to right above in an early panel session. Russell was still standing at the end.

‘Cost to serve’ is obviously topical.

Dealing with consumers with characteristics of vulnerability was a key theme and how, with the right treatment paths, this allows continued collection of outstanding balances (e.g. taxes, council tax). Forbearance measures coming out of the pandemic was a major reference point. For example, the Head of Debt Management at DWP said that at the start of the pandemic, DWP switched off debt management in just 14 days, but turning it back on took over a year. Major central government bodies have taken a cautious approach to avoid consumer detriment.

There is an industry-wide aim to improve self-service capabilities, driving an adoption of omni-channel approaches and freeing up limited agent resources to focus on the more complex call types and with the customers best suited to this channel. Workplace wellbeing and agent capability to deal with these more complex calls at scale is also a priority referenced by both DWP and HMRC in the ‘What does good debt strategy look like?’ session at the end of the day. FourNet has identified this aspect of Social Value, where many emergency call handlers are dealing with a constant stream of calls from people showing characteristics of vulnerability.

There is a clear need for a customer centric approach and more channel choice across many legacy systems. Transformation planning is complex and can take many years over many budgeting and strategic review cycles. Legacy systems remain a major barrier to change and ‘cloud first’/’digital first’ strategies are still inconsistent across government agencies.

There were some very interesting sessions around data sharing under the Digital Economy Act 2017 (DEA) with both fraud prevention and vulnerability assessment goals. James Elliott of Cabinet Office kicked this off in his keynote session and the Public Sector Fraud Authority (PSFA) expanded on later in the day, including the role of private sector collaborations. I was really please to hear mention for the Vulnerability Registration Service in Art Mitchells-Urwin’s (PSFA) talk on the Digital Economy Act (DEA) data sharing initiatives.  

As a provider to many government bodies at a central and local government level, supporting many procurement frameworks, the requirements for highly secure infrastructure enabling data sharing, data analytics and intelligent routing in CCaaS and self-serve environments has never been more acute. Customer Experience (CX) and Employee Experience (EX) appear to be very much front-of-mind.

My thanks to Bill Cooper of FourNet for the link to their one minute overview of the essential services that they provide to the likes of the ‘blue light’ services and other public sector partners.           

See also  DEMSA update: StepChange is 30 / Data Privacy Day / Consumer Duty / ISO 22458 / AI use by local authorities / Events

Debt Relief Order (DRO) update

I also mentioned in last Saturday’s bulletin that The Insolvency Service has provided an update on DROs in the last year since the eligibility criteria were changed in June 2021. Sam Roberts at The Insolvency Service provided an update on Personal Insolvency reform at the Gov-Debt event in London yesterday that I attended. She also provided a Breathing Space update one year on and referenced some of the statistics recently circulated by DEMSA that are based on StepChange’s annual review of Breathing Space covered in July 2022.

There were 1,812 Debt Relief Orders (DROs) in September 2022, which was 16% lower than September 2021 and 26% lower than the pre-pandemic comparison month (September 2019). By contrast, 535 personal bankruptcies were registered in England & Wales, which was 15% lower than in September 2021 and 61% lower than September 2019.

The table below presents the estimated numbers of DROs between 1 July 2021 and 30 June 2022 where the individual was eligible as a result of the change to each criterion. For example, there were 4,460 individuals who obtained a DRO who had debt over £20,000, but were within the previous limits for assets, vehicle value and surplus income. “Two criteria” represents individuals who exceeded the previous limits on two of the criteria (e.g. surplus income and assets); “Three or four criteria” shows the number of individuals who exceeded at least three of the old criteria.

CriteriaNumber of DROsPercentage of newly eligible DROs
Debt only4,46051%
Surplus only1,79621%
Assets only1091%
Vehicle only97211%
Two criteria1,23614%
Three or four criteria911%

Insolvency statistics – September 2022

In England & Wales in September 2022, there were 1,379 Creditors’ Voluntary Liquidations (CVLs), 4% higher than in September 2021 and 25% higher than September 2019. This made up the majority of the 1,679 insolvencies. In September 2022 there were 103 company insolvencies registered in Scotland, 47% higher than the number in September 2021 and 36% higher than in September 2019. This was comprised of 25 compulsory liquidations, 69 CVLs, eight administrations and one CVA. There were no receivership appointments. In September 2022 there were 22 company insolvencies registered in Northern Ireland, this is double the number in September 2021, but 39% lower than September 2019. This was comprised of two compulsory liquidations, 18 CVLs and two CVAs. There were no administrations and no receivership appointments.

Personal insolvency

See above for DRO and personal bankruptcy figures in England & Wales in the DRO update. There were, on average, 7,188 IVAs registered per month in the 3-month period ending September 2022, which is 5% higher than the 3-month period ending September 2021, but 4% lower than the 3-month period ending September 2019. IVA numbers have ranged from around 6,300 to 7,800 per month over the past year.

In September 2022 there were 152 individual insolvencies in Northern Ireland, 24% higher than in September 2021, but 52% lower than September 2019. This consisted of 120 IVAs, 24 DROs and eight bankruptcies.

Breathing space

There were 6,177 Breathing Space registrations in September 2022, which is 21% higher than the number registered in September 2021. 6,085 were Standard breathing space registrations, which is 21% higher than in September 2021, and 92 were Mental Health breathing space registrations, which is 10% higher than the number in September 2021. We are tracking the rise in standard breathing spaces going into 2023. Having the debt advice provider breakdown would be useful.


Product Development under FCA Consumer Duty (PS22/9), Principle 12 and PRIN 2A

I posted a thought piece on the DEMSA LinkedIn forum around applying the Consumer Duty rules to Statutory Debt Repayment Plans (SDRPs). This may be of interest to many on the circulation list with implementation plans imminent. This goes into more detail around PRIN 2A.

Steve Coppard also picked up on Peter Wallwork’s article on SDRPs.

Google Ads Financial Products & Services Policy from December 2022

On a related topic around Financial Promotions, I have posted an update by Google that has been strongly supported by MaPS and StepChange Debt Charity, which DEMSA is aligned with.

The Google policy will be updated to require that all advertisers be FCA authorised for debt adjusting and debt counselling in order to show debt services advertisements starting from 6 December 2022. I will monitor for updates from ASA/CAP. CAP published a piece on the ‘dos and don’ts of lead generation advertising’ on 6/10/2022.

Insolvency practitioners, including those licensed by a recognised professional body (RPB), will no longer be allowed to advertise for these services. Advertisers must successfully complete the updated verification process by the time enforcement begins on 16 January 2023.




Craig Simmons and Phil Andrew have both made strong statements on LinkedIn this week.

VRS Consumer Duty Training – 17/10 and 31/10

I have published a bulletin on these events and details can be found at the VRS post.

This training workshop will focus on the practical actions that you can undertake to prepare for Consumer Duty.

Learning outcomes:

  • To understand the practical implications of Consumer Duty for your firm
  • To know what the Consumer Duty requires of your firm
  • To be able to create a framework of action regarding each vulnerability type
  • To be able to identify the practical actions required in order to meet the FCA’s expectations
See also  DEMSA update: SDRP consultation / Inclusive design / Dear IP / MaPS BNPL concerns / Breathing Space / Events


‘Mixed message’ launch at FCA on 15/11/2022

At Minesh has asked me to promote the event on 15 November 2022. I have copied Minesh above.

As covered in the DEMSA bulletin last week, StepChange has worked with Amplified Global to assess the extent to which communications to consumers in financial difficulties helped people take action to resolve their debts. You are invited to attend the report launch at the FCA and panel discussion on how to design communications so they are better understood by consumers. Alongside the research, the expert panel will discuss how behavioural science, linguistics and psychology all have a role to play in improving comprehension of communications.

I am very much looking forward to attending.


It is getting difficult to keep track of all the events going on.

Trustfolio interview

Some of you may have seen the video teaser and the actual podcast from my interview with Lee Usher and Peter Wallwork from Trustfolio in Episode 5. I must admit it was fairly painless and aside from having to delve into the memory archives for Rugby question answers, the focus was on issues facing the sector now and into 2023. Some interesting disclosures around Peter’s sauna/steam room habits that are now on record.


PayPlan regional roadshows in October and November

I have circulated a bulletin this week on the upcoming PayPlan roadshows including Gamcare. Emma Gibbons ( and Antony Price ( of PayPlan are in the process of delivering Autumn roadshows in Bristol, Birmingham and Lewes. The dates and locations are as follows :

  • 18th October Bristol
  • 19th October Birmingham
  • 30th November Lewes

They are thrilled to announce that Gamcare will also be joining them for the events to discuss their findings with the cost-of-living crisis – what impact this is having on their service users , their community and affected others and the support on offer to debt advisers with their resources and free training. This is fairly topical at the moment with the Vulnerability Summit on 7/11/2022 where I am speaking about gambling.

MALG has been promoting the events as well.

FCA webinars

As we approach the first Consumer Duty milestone on 31 October 2022, we have a series of FCA webinars around Consumer Duty expectations and key topics like Financial Promotions. Some of these are sector specific.


Consumer Duty and workplace culture – 27/10/2022

My thanks to Garry Gormley of The FAB Group for posting on this. Featuring Chris Jones from VCX. I am expecting that this will pick up on some of the challenges that FourNet has highlight around workplace wellbeing, where the cost-of-living crisis may put more pressure on contact centres and their staff, where hybrid working is a key strategic planning factor.


Open Banking Expo UK – 20/10/2022

There are now some discounts being offered on this event. Even with 50% discount, it is still relatively expensive.   


MALG Annual Conference – Birmingham – 3/11/2022

I am looking forward to supporting one of the panel sessions – Breakout 2a: Looking back, looking ahead: 35 years of lending, collections and debt advice.



Vulnerability Summit moved from 5/10 to 7/11 at the Brewery, London

This event has now been re-arranged because of the rail strikes and I am looking forward to the panel session on gambling. Denise Crossley and Chris Fitch are doing the welcome, with Lantern as main sponsor and Experian as ‘knowledge sponsor’.

We are covering:

  • What measures can and should be put in place
  • Gambling and regulation
  • Gambling limits – technology available
  • Responsibility of the lenders

I think that Sonya Schofield from Studio Retail is now supporting the event.  



BSI ISO22458 webinar – 9/11/2022

There is a free webinar for those firms who fall into the BSI ‘generic’ scheme (i.e. not Financial Services, Energy or Water) for ISO 22458/Inclusive Service Kitemark on the 9 November 2002


Debt Management Connected – 10/11/2022

text and logo along with a picture of a person

I am hoping to support this event that Heidi ( is running. Is was good to catch up with Muna Yassin MBE (Fair Money Advice) and Hoss (Elifinty) at Gov-Debt. The Fair Money Advice pictures are better than mine. 

Credit-Connect Think Tank and Awards Dinner – Midland Hotel, Manchester – 17/11/2022

Another event to look forward to. Chris Warburton is chairing the Think Tank during the day and we have the awards in the evening with many on the circulation featured (see shortlist below).

Sponsors are Callminer along with Data on Demand, DebtStream, Experian, Receeve and Allied International Credit (Outsourcing and DCA).



Credit Strategy – Collections & Vulnerability Summit – Midland Hotel, Manchester – 30/11/2022

I am looking forward to speaking at this event on 30 November 2022, again at the Midland Hotel, Manchester. Lantern and Just are featured sponsors along with a number of other familiar names with much larger marketing budgets than DEMSA. I am an available dinner companion if anybody is wondering.



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