DEMSA update: FCA report / MALG conference / Interest rates / Consumer Duty / Events

General update

The interest rate rise by 0.75% to 3% was not unexpected, but will result in many mortgage holders being worried about what this means to them in 2023 and beyond. StepChange has commented on this and Karl Handscomb, Senior Economist from the Resolution Foundation, painted a fairly gloomy picture for the next couple of years at the MALG Conference as part of an interesting keynote alongside the FCA. At present, around 15% of mortgage holders that seek help from StepChange are in arrears on their mortgage at the time they seek advice. StepChange has warned that the knock-on effect of higher mortgage costs means that, even if people manage to keep up on their mortgage, there is a higher risk that they won’t be able to maintain their other financial commitments and pay other bills. This will be a key part of horizon scans for new debt advice sessions and at the time of reviews, along with the energy cost projections and other factors outside of the direct control of consumers.

At its meeting ending on 2 November 2022, the MPC voted by a majority of 7-2 to increase Bank Rate by 0.75 percentage points, to 3%. One member preferred to increase Bank Rate by 0.5 percentage points, to 2.75%, and one member preferred to increase Bank Rate by 0.25 percentage points, to 2.5%. CPI inflation was 10.1% in September 2022 and is projected to pick up to around 11% in Q4 2022.



Chris Warburton interviews Ken Doherty at Cerebreon

Chris discusses machine learning (ML) with Ken at Cerebreon. As a fellow mathematician, I obviously fully understood everything he said. The full interview is available at the link below.


Congratulations to Hope Macy on becoming a credit reference agency

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Well done to Sam Manning and the team at Hope Macy. I managed to catch-up with Lee Healey (IncomeMax) after his emotional presentation at the end of the MALG conference. Sam and the team have been collaborating with IncomeMax in re-platforming their service to provide more capacity using Salesforce and embedding open banking. It is a very practical example of trying to deliver the very personal service illustrated by Lee in his video footage with the use of technology to allow agents to be more productive and efficient.   


Recruitment and new starters

Hoss Atri of Elifinty is looking for a Community Engagement Executive.  

Laura Dale-Gough has recently started as a BDM at IE Hub. I managed to decline the IE Hub branded cup cakes on offer from Gareth and Mark at the MALG Conference stands.

I also managed to catch-up with Ammer Malik, Head of Business Development at PayLink, at the conference.

Bev Budsworth is up for a significant IPA award on 5 December 2022 in London. Debt Movement UK is one of the sponsors.  

As I was reflecting to Marco at Perch, I am sure we will be catching up frequently over the coming weeks at various events and awards dinners.   

NCSC update

The National Cyber Security Centre (NCSC), the government agency that leads the country’s cyber security mission, is now scanning all Internet-exposed devices hosted in the UK for vulnerabilities.

The goal is to assess UK’s vulnerability to cyber-attacks and to help the owners of Internet-connected systems understand their security posture.

This is designed to help to:

  • better understand the vulnerability and security of the UK
  • help system owners understand their security posture on a day-to-day basis
  • respond to shocks (like a widely exploited zero-day vulnerability)


Priority Service Register (PSR)

Registration for the PSR is coming up in more and more discussions. This site may be of use for debt advisers and others. This relates to gas supply. The criteria for eligibility are very broad:

  • over 65
  • have children under five or are pregnant
  • have long-term physical or mental health conditions
  • have a disability
  • have additional language or communication needs
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The Insolvency Service customer service research summary

As in previous years, the Insolvency Service derived satisfaction scores this year across all customer groups was high, with few significant changes on previous surveys.

Overall derived satisfaction was 84%, up 1% on the previous year. Amongst different customer groups, the highest derived satisfaction score was seen among DRO debtors (93%), which is encouraging.


UK Finance – how consumers use cash

The UK Finance Watching Our Pennies report found that almost 40% of people use cash to pay for something at least once a week, with 11% saying that they prefer to use cash and only 3% saying that they never used cash at all. The youngest respondents (16–24 years old) were widely expected to be non-cash users, but used cash almost as regularly as the 45-54 age group. I must admit that several recent car parking incidents in Manchester and Birmingham have made me nervous around the lack of traditional payment options. I really don’t like paying by QR code or app. Indeed, I asked the parking attendant when exiting the Birmingham car park after the MALG event to show me on his tablet that my car was paid for. He showed me a list of vehicle registrations with a traffic light sign next to them. Mine was on Amber (near end of payment period), but OK.

The most common reason given for using cash was as a budgeting tool, although a third of people like it as they feel it is a safer way to pay than other methods. 6% of people don’t trust banks and 15% don’t trust technology. 4% of people are still paid their wages in cash.


FCA – Borrowers in financial difficulty

I have attached the email from Matthew Sherratt at the FCA around the ‘Borrowers in financial difficulty’ report that was published on the day of the MALG conference and referenced by Ian Searle of the FCA, who provided a keynote speech by video link at the event. Sheldon Mills has also posted a Blog on this topic and commented:

“To be clear, we are not asking lenders to carry out debt counselling activities. We are only asking that lenders consider what more they can do to help consumers understand the potential benefits of debt help or money guidance and to help them access these services, such as through the government backed MoneyHelper service.”


Bob Winnington managed to relay my question at the MALG Conference to Ian (pictured above) around data sharing and the role of UKRN in co-ordinating some of this across regulatory bodies, notably around vulnerability. We have been liaising with Cabinet Office around the Digital Economy Act data sharing schemes between HMRC, DWP, local authorities and essential service providers. The Vulnerability Registration Service (VRS) is involved in these discussions. The ‘tell us once’ approach seems to be gathering some momentum and the Consumer Duty will help this.

I attended the FCA webinar on 1 November. Jonathan Phelan made some really strong points around addressing ‘root cause harms’. He focused on 4 key harms, one material to the regulated debt advice sector:

1.         affordability assessments (notably those that can have a life changing impact)

2.         tailored forbearance

3.         unfair charges (surprise charges during the lifetime of an agreement)

4.         quality of debt advice (notably outcomes from single product providers)

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Aveni has also picked up on a few points made by Jonathan Phelan in his section of the FCA webinar.


Meanwhile, Therese Chambers, FCA Director of Consumer Investments, delivered a speech on 2 November 2022 at the Festival of Financial Planning in Birmingham. The speech focused on more consumers who can afford to do so investing their money safely. Fraud and scam awareness feature prominently. I also suspect that this follows on from the worrying adverts on TV around non-advised investments, where consumers play ‘follow my leader’ and pay for investments by credit card and don’t realise that they lose money.

The hazards have grown in size – recently published FCA data shows an increase in adults now holding high risk investments, up to 5.7m, and a 47% increase in reported investment fraud losses in financial year 2021/22 compared to 2020/21, up to £915m.

I have commented on Point 4 above in the LinkedIn post, where the latest FOS quarterly statistics suggest that complaints around regulated debt advice are minimal with no recorded uphold rate. There does seem to be a dis-connect between the Top-5 most complained about items and the items singles out by the Consumer Finance team.




Training on Consumer Duty and PRIN 2A

I delivered the Consumer Duty training with VRS during the course of October and we are planning on more sessions going forward. These will reflect some of the key messages from the FCA.

The shift from TCF was discussed a number of times at the MALG conference and in the FCA webinars.  

Data sharing initiatives

We recently featured Art Mitchells-Urwin, Counter-Fraud Business Development & Operations Manager at Cabinet Office, after Gov-Debt in October 2022. He has posted on LinkedIn regarding the data sharing initiative between local and central government agencies that the Vulnerability Registration Service (VRS) has been involved in.

He has appealed to Local Authority colleagues in England, Scotland and Wales, where the Digital Economy Act Team is holding a hybrid meeting (online and in-person) on the 15 November (1.30-5pm) to detail the progress they have made with the Council Tax Debt data sharing pilot (with HMRC and DWP data), to understand requirements for data sharing as business-as-usual (BAU) and to outline how they envisage this can be achieved at pace for each Local Authority. This topic obviously came up in the FCA and SDRP presentations at the MALG Conference (in part through some questions by me).

This is a really important opportunity for each Local Authority to guide this work and to progress their involvement in the BAU data sharing.

This is an example where words can be put into action and with private sector involvement.

MALG conference – SDRPs

Great event. I am planning on some follow-ups, including Mike Ellicock of Plain Numbers ( who spoke in the Big Debate with Muna Yassin MBE, Steve Coppard and Matt Dronfield. Payplan joined forces with Plain Numbers in 2021 to help support their customers who struggle with numbers and data. There are a lot of synergies with what Amplifi is doing with StepChange on the literacy side, which I raised in my question to Mike during the Q &A session. I managed to keep catching the pink Q & A cube that was being thrown around the main arena. Heidi and Bob caught on video showing the model technique to avoid embarrassment if you ‘drop the ball/cube’.   

Statutory Debt Repayment Plans (SDRPs) were discussed at length at the MALG conference. Peter Tutton led a lively debate on this at the conference and Steve Coppard and I contributed to this in the Q & A session. One to be continued I am sure. Chris Leslie has picked up on this on LinkedIn. Quite a few responders from the bulletin circulation list already.  

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I bumped into Craig Simmons and a number of the MaPS team at their stand and around the conference. Just a reminder that their deficit budget call for evidence closes on 1 December 2022. I have attached the call for evidence, which was being handed out on the MaPS stand.


FOS complaints – July to September 2022

It is interesting that Jonathan Phelan of the FCA included the quality of debt advice in the 4 ‘root cause harms’ when you contrast this with the latest FOS quarterly stats for Q2 (2022/23 – July to September 2022). Monitoring complaints and root cause analysis has been referenced many times by the FCA in FG22/5, webinars and speeches as a key metric.


Unsurprisingly, the top-5 most complained-about products were:

  1. Current accounts – 5,945
  2. Credit cards – 3,386
  3. Car or motorcycle insurance – 2,729
  4. Hire purchase (motor) – 2,149
  5. Personal loans – 1,678

Debt counselling/advice (including Debt Management Plans) had 19 new cases and a nil uphold rate. Debt adjusting didn’t really trouble the scorers. It is noticeable that the FOS site doesn’t feature ‘quality of debt advice’ on its key pages. These are dominated by unaffordable lending and fraud & scams. It will be interesting to see if the FCA interventions around poor tailored forbearance measures results in more complaints rather than just voluntary compensation/redress by the firms that have been investigated by the FCA.  

I have attached the spreadsheet, which highlights relatively low complaints for those holding debt collection permissions with only 187 new cases and a 28% uphold rate.

Ombudsman News (Issue 175) covers fraud and scams.  



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


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

Minesh has asked me to promote the event on 15 November 2022. I have copied Minesh above. I am looking forward to attending.  

Credit-Connect Think Tank and Awards – 17/11/2022

We are seeing many on the circulation featured ahead of the Awards dinner on 17/11/2022. I am looking forward to attending. This features a number of collaborations, including essential service provider like IE Hub and United Utilities. DebtStream and Qualco are in the same category for best use of technology alongside Webio and LendingMetrics.  

Chris Warburton is chairing the Think Tank during the day.



Vulnerability Summit – 21/11 at the Brewery, London

We are covering:

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



Cost of Living and Board Risk – Transpire NED event 21/11/2022

I am pleased to be supporting a panel session on the cost-of-living crisis on 21 November 2022.

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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