DEMSA update: Consumer Duty / Steve Coppard Blog / Chatbots / Financial Wellbeing / Events

In today’s bulletin

  • General update
  • Steve Coppard Blog on Consumer Duty
  • How can financial institutions support the financial wellbeing of their clients?
  • ChatBot research – call for input
  • Training
  • Events

General update

I published a bulletin last Sunday on CP23/5 (Debt Packagers) and the SIP 3.1 changes that take effect in March 2023. I have had a number of calls and meetings around responses. This is particularly relevant to any firm that may be inadvertently caught in the FCA restrictions. This may be firms that have an Appointed Representative within a group under the same ownership. It can be debt advice providers that don’t operate debt packager models where there are no material conflicts of interest and there is evidence of high-quality debt advice through recognised QA checks. We are exploring whether a waiver option should exist where non-alignment with what conduct the FCA wish to stop can be evidenced. The issue appears to be that the FCA don’t really want to supervise small regulated firms or monitor the perimeter.      




Richard Church from 4most provided a good economic summary at the Credit Union and Community Banking event last week sponsored by IE Hub and run by Chris Warburton. More on this below.   

UK house prices stabilised in January 2023 after a fall in the final months of 2022 according to Halifax. Consumer spending remained broadly below inflation in January, according to data from the British Retail Consortium. The UK is likely to avoid a recession this year, the National Institute of Economic and Social Research (NIESR) has predicted, adding that the economy will grow marginally despite high prices hitting household budgets. The Bank of England doesn’t seem as optimistic. NIESR has also said low and middle-income households were facing the biggest financial hit from the cost-of-living challenge, with households expected to suffer a hit to their finances of up to £4,000 this year. According to ONS, the UK economy showed zero growth in the final 3 months of 2022, thereby avoiding being in a recession.

Andrew Bailey has told MPs that its forecasts for inflation to more than halve this year are at risk from price and wage-setting as unions continue to demand large public sector settlements. Strikes are impacting productivity.

UK Finance has confirmed that the level of homeowner mortgages in arrears edged up by 1% in Q4 2022 compared to the previous quarter. Homeowner mortgages in arrears of 2.5% or more of the outstanding balance came to 75,170 in Q4 2022. At the start of February 2023, StepChange’s client data showed that 17% of new clients are in arrears with their mortgage, an increase of 2% from November to December 2022.


Eviction claims by private landlords hit a 23-year high in 2022, according to government figures. The number of people forced out of rented homes in England & Wales hit 5,409 in the last 3 months of 2022 as rental evictions continue to build up following a ban during Covid.

On a related topic, there is an interesting Blog on the mortgage application process which may be of use to providers and those looking for a mortgage.



According to the ICAEW published by the BBC, understaffing at HMRC is causing unacceptable delays and hindering economic activity. ICAEW said that securing basic tax details takes months and is causing delays for companies. HMRC acknowledged there were problems, some of which derived from what it described as “a significant attack from VAT registration fraudsters” in July 2022. HMRC said that it had collected a record £731 billion in tax last year.

Guest blogs

Following an exchange on LinkedIn, I am delighted to have a guest blog from Steve Coppard of Arum regarding a debate in the House of Lords around the Consumer Duty. I am hoping these type of blogs can become a regular slot and bring some variety to the Saturday bulletin. I discussed this with Rachel and Graeme at Inicio AI yesterday. Congratulations to them on moving on progressing to the next round in the Tech Nation rising stars competition. Tech Nation has announced the 33 Regional Winners in the fifth iteration of their early stage scaleup competition, Rising Stars.

See also  DEMSA update: SDRP consultation / Inclusive design / Dear IP / MaPS BNPL concerns / Breathing Space / Events


Perch Group’s CEO, Craig Hinchliffe, has been named as a Finalist in the ‘Business Leader of the Year. We wish him all the best in winning this category. I can see on the LinkedIn post that he has a number of likes, including many from outside Perch. Spotted Gary Gilburd from Sigma, Sam Bedford from Auden, Peter Gent from COEO, Simon Gregory from Data on Demand and Martin Prigent from Aryza. The list goes on. 127 likes at the time of writing.

Lobby to postpone the planned energy bill rise in April 2023

CAP has posted that more than 20 consumer organisations and charities, including us have supported MoneySavingExpert’s call to postpone the planned energy bill rise in April, following their letter to the Chancellor. The letter requests that the chancellorreverse plans to raise energy bills from April or risk 1.7m more households falling into fuel poverty. Energy bills for a typical household are set to rise from £2,500 to £3,000 a year and the £400 discount will also end. Jeremy Hunt has so far ruled out extra support.

MaPS has been promoting the help available this week –

Dear Chancellor, postpone planned April energy price hikes and keep the energy price guarantee at a typical £2,500 a year - or millions will fall into fuel poverty. Organisations that agree: christians against poverty, epilepsy action, citizens advice, warm this winter, scope, fair by design, ageuk.

Chris Fitch has been featured on the FSCS site – – Money Advice Trust talks about consumers managing their money with confidence.

IncomeMax social impact report

Dan Woodhead has posted on the IncomeMax social impact report. The report can be downloaded from the link below.


Credit Summit 2023 – my 60 second interview

This is available at the link below where I have been asked to horizon scan into 2023 and look at the world of Collections Strategy. Full details of Credit Summit 2023 are in the Events section.


Compliance Officer vacancy at Firstsource

Spotted Steve Exton’s post on LinkedIn for a Compliance Officer. Very important role in the current climate.

Meanwhile, Firstsource has undertaken an interview suggesting the cost-of-living and tighter consumer spending to see extra 148m customer service enquiries. Those with incomes in the bottom 20%, under £17k per year, are likely to account for 38% of additional calls to energy providers and 34% to financial services companies.


Bennett Jones is also hiring – Compliance Oversight Manager

I spotted this post from Mark Smith this week. This also includes a Compliance Oversight Manager amongst several roles available.

Hope Macy is looking for C++ developers in Wales

Sam Manning has posted on LinkedIn.

UK cracks down on ransomware actors

My thanks to Niran Seriki for his cyber-security alerts.

Seven Russian nationals have assets frozen and travel bans imposed. Ransomware is a tier 1 national security threat, with attacks against businesses and public sector organisations increasingly common. Recent victims include UK schools, local authorities, and firms – whilst internationally the Irish Health Service Executive, Costa Rican government and American healthcare providers were targeted. New campaign of concerted action is being coordinated with the US, after 149 British victims of ransomware known as Conti and Ryuk were identified by the National Crime Agency (NCA).


Episode 7 of Trustfolio interviews – David Hawkes

Episode 7 of the Trustfolio debt-tech podcasts will be available next week with Lee Usher and Peter Wallwork engaging with David Hawkes. Apparently, David succinctly dissects the problems facing debt advice and what’s needed to overcome the huge challenges ahead. Should be interesting.

Preview has been posted as a teaser.

Zilch partners with StepChange

BNPL provider, Zilch, is integrating StepChange Direct into its platform and is also promising to “go one step further and provide innovation that will better advance the user experience”. Zilch is also making financial contributions to StepChange through the Fair Share funding mechanism, supporting the charity in its operations.

In the UK Finance news, they have quoted that £1 in every £8 spent online in January 2023 was sourced from BNPL providers (according to research by Adobe Analytics).


Good Lord!

This week, the Consumer Duty came under fire in the House of Lords as part of the Financial Services & Markets Bill reading.

Amendment 76 boiled down to dissatisfaction that the Duty as proposed is not a Duty of Care, and therefore has these perceived flaws:

  1. There is no private right of action (PROA) for breaches. The FCA consulted on this (see CP21/13) and it would be easy to write 50 pages on the options, but the long and short of it is that a PROA would enable more claims to be processed under the Financial Services Compensation Scheme.

    The downside is that the cost of a private action is high in the first place, plus the losing party in any claim is likely to have to pay the other party’s costs. From a commercial perspective, providers would be likely to price in risk by increasing the cost of products and services across the board, alongside narrowing their exposure by reducing the breadth of products and services available.

    The conclusion I draw from this is that there are pros and cons to each approach, the FCA consulted on it and made a decision, which the Lords are now questioning – as is their right – while the rest of us mere mortals wait with baited breath!
  2. The second perceived flaw was that it isn’t compulsory to publish information on compliance with the Consumer Duty, therefore it will be difficult to judge its impact.
  3. The third perceived flaw – and the one that I suspect will resonate most clearly with people – was that firms have to comply based on the “reasonable expectation” of consumers. A lot of debate on precedents followed, but it was summed up as “lacking in clarity and definition”.
  4. The fourth and final perceived flaw was that because the fair value assessment requires firms to effectively benchmark themselves against each other, then they could carry on exploiting people as long as none of the firms tried to improve.

    I kid you not! They actually said that rather than a race for the top, Consumer Duty could lead to firms collectively entrenching themselves in bad behaviour to game the outcome of the benchmarking! This stuff is better than Game of Thrones!

The proposed amendment was subsequently withdrawn. Do feel free to unbait your breath.

See also  DEMSA update: Consumer Duty / Financial Crime / MaPS SFS tool / Vulnerability / Cost-of-Living / Events

Should you be a glutton for punishment, you can find the full transcript here.

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Steven Coppard FCICM – Group Director of Debt Policy and Strategy

How can financial institutions support the financial wellbeing of their clients?

MaPS is promoting a video on YouTube that is encouraging Financial Service firms to better support Financial Wellbeing. It references a case study from Nationwide Building Society.

There is obvious alignment with the FCA Consumer Duty expectations around consumer understanding and messages that Amplified Global™ and Plain Numbers have been strongly pushing around financial literacy and numeracy levels. Minesh Patel made very strong points at a number of events in November 2022 around ‘intelligibility’. Behavioural science features strongly in the MaPS video.

Capable and confident frontline staff are key to this along with technology enablement. The tone is set from the top. That is why I have been a fan of the new BSI ISO 22458 kitemark around inclusive design and vulnerability management.


ChatBot research project

Chris Warburton and I are about to start some research work into Chatbots as part of a broader review around digital transformation. If you are interested in participating then drop me ( or Chris a line. Chris is copied. He has been fairly busy of late. I spotted a recent interview with Guy Statter of Qualco. 

Chris has been running a snap poll titled “When attempting to initially engage a customer in collections, which channel is currently more effective?”. ‘Digital and messaging’ is looking a strong contender at the moment. Chris has posted that if you would like to receive the full benchmarking report versus your peers then you can access all the questions via the link below.


Meanwhile there is a BBC story entitled “Have we fallen out of love with voice assistants?”. Voice assistants, such as Amazon’s Alexa, Google Assistant and Apple’s Siri, enable users to control IoT devices by voice command. The news featured headline stories of major tech providers laying of thousands of employees (e.g. Yahoo, Salesforce).

The Google Bard AI bot mistake wiped $100bn off shares, which probably hasn’t helped their cause. Rivalry between Microsoft and Google in this space is ‘hotting up’. The thinking was that the advent of smart devices like Google Home and Nest, and voice assistants like Siri and Alexa would further increase traffic to the voice channel. These cloud-based voice assistants, aided by speech recognition and Natural Language Processing (NLP) have become an unexpected mass-market driver of voicebots in contact centres.

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I feel a blog coming on.

Consumer Duty Training

The next round of Consumer Duty training commences on 20 February 2023. Kirstie and Heidi are organising and are copied if you are interested. I am looking forward to supporting this Vulnerability Registration Service (VRS) training & development event and to see how far we have come since the training in October 2022. As reflected above, the FCA has continued to communicate their expectations and findings from implementation plans they have reviewed to-date. Surveys now move on to smaller firms and those that have changes planned or in progress with the FCA are likely to have to submit their Duty plan as part of this process. I will update with the “Dear CEO” letter content through February 2023.   

Please choose one date from the list below (all £195/person/session or £150/person/session when booking for more than one person from the same organisation):

  • 20 February 2023, 1.30-4.30pm
  • 27 February 2023, 1.30-4.30pm
  • 13 March 2023, 1.30-4.30pm
  • 20 March 2023, 1.30-4.30pm



The Credit Union and Community Banking event on 7/2/2023 was well attended. Chris chaired the event sponsored by IE Hub. Richard Church from 4most set the scene with an economic overview, followed by Dylan discussing IE Hub’s 2022 findings and the impact of income optimisation. This provided a platform for Manu from InBest to look at social tariffs in water, energy, broadband and mobile phones. Helen Lord from VRS provided some vulnerability updates. We had a video from Cath at Stop Loan Sharks England.

Attendees and those registered to attend should have received an email from the event with the recording and attachments, including the survey results featuring appetite to share more data (including I & E data).

VRS – Local Authority event on 13/2/2023

On the theme of data sharing amongst local authorities, this important event will feature several case studies, including Kent.


  • 09:15 – 09:30   Registration Arrival & Networking
  • 09:30 – 09:40     Welcome and Housekeeping – Kirstie Gatter, VRS Client and Partnership Liaison Manager & Chair / Heidi Oliver, Absolutely Admin Hosting Support
  • 09:40 – 10:00   Event Introduction and VRS Update – Helen Lord, CEO; VRS
  • 10:00 – 10:15    Working with VRS and ReferKent Service – Stacey Clark, Project Manager/Referral Lead; Kent County Council
  • 10:15 – 10:30  Data Protection Myths Busted – Rob Bell, Compliance Consultant; RB Compliance
  • 10:30 – 10:50      How Sharing Data can Reduce Embarrassment and Upset for Vulnerable Customers – Caroline Thomas – Customer Experience; Fournet
  • 10:50 – 11:00   Reflections of the Day & Close – Kirstie Gatter, VRS Client and Partnership Liaison Manager & Chair – VRS

Ascendant Solutions has also just announced its collaboration with InBest.

Event link:

Public Sector Customer Forum – 16/2/2023

Matt Hooper (Crown Commercial Services) has been promoting this event on LinkedIn.

IE Hub has been supporting financially vulnerable customers for over 4 years and are joining on the 16 February at 10am to provide their insight, at the CCS Revenue, Recovery, Analytics and Data (RRAD) customer forum.

Gareth and team will be discussing areas including:

  • The importance of understanding Income & Expenditure
  • Why the current, typical approach to capturing Income & Expenditure information is broken
  • How to increase engagement with consumers
  • How data sharing benefits both the consumer and service provider

As reflected above, data sharing is obviously a ‘hot topic’ at the moment.  

Online Collections Technology Think Tank 4.1 – Thursday 23/2/2023

Speakers include Jamie Buckley from StepChange and Ian Parry from Utility Collections.


Credit Strategy Credit Summit 2023 – 16/3/2023

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