Interesting discussion across the 4 sessions, building on the regulatory and data theme.
- Regulatory pressure intensifying, with smaller lenders feeling the greatest strain.
- AI adoption accelerating, but only working well where data discipline is strong.
- Growing financial stress among customers, especially those already struggling.
- Transparency demand is surging, with DSAR volumes rising sharply.
- Increased reliance on behavioural insights to drive engagement and outcomes.
- Firms shifting towards personalised, data-driven communication.
- Omnichannel flexibility becoming essential – customer preferences are changing more frequently.
Key takeaways from each session
Session 1: Addressing Industry Challenges
Key Take Aways
- Regulatory change and data demands (e.g. product sales data and consumer duty) are creating sustained, existential pressure for smaller and specialist lenders.
- The volume and ambiguity of new reporting requirements, particularly product sales data, is high and difficult to operationalise, even for firms with strong data capabilities.
- Consumer duty has sharpened thinking and led to some positive improvements, but has also significantly tightened affordability and reduced access to credit in some markets.
- Lending volumes in certain specialist markets have fallen dramatically, leaving some communities without access to needed credit.
- Financially vulnerable customers are struggling more deeply, even where overall arrears and delinquency volumes appear broadly stable.
- There is a growing wave of digitally driven disputes, DSARs and complaints, fuelled by online content, CMCs and changing consumer expectations.
- Smaller firms face a disproportionate burden from regulatory change and technology investment, particularly given static FCA fee levels since 2014.
- The opacity of the FCA’s “real” expectations (e.g. around affordability) and retrospective reinterpretation of rules create material risk and cost for firms.
- Technology and AI are increasingly used to monitor compliance, identify vulnerability and support customer education, but raise new risks around definitions, nuance and data volumes.
- Enforcement and collections sectors are capturing far more data (recorded calls, body-worn video, case data), which can both protect firms and expose them to more regulatory challenge.
- Perceptions of the collections and enforcement industry remain a major issue; better data, oversight and public education are seen as critical to shifting this.
- Large-scale regulatory data collection (product sales data and other datasets) may drive blunt, outlier-based supervisory action, with particular concern for sub-prime and specialist lenders.
Innovatation
- Use of AI and automation to interpret complex product sales data requirements and streamline regulatory reporting.
- Application of AI to detect intent and vulnerability from speech and interaction data, enabling smarter routing and tailored questioning.
- Voice analytics and similar technologies to help collections firms identify vulnerable customers consistently at scale.
- Behavioural and educational interventions, such as reward programmes focused on “using credit responsibly” and explaining the impact of missed payments.
- Rules-based and workflow systems in enforcement that automatically flag potentially vulnerable cases (e.g. repeat tickets, long histories) for human review.
- Sector-wide data gathering by voluntary oversight bodies (e.g. Enforcement Conduct Board) to evidence actual industry behaviour and challenge misconceptions.
- Use of comprehensive recording (all calls, three-way calls, video evidence) to protect both firms and customers, while supporting complaint and DSAR handling.
Key Statistics
- One member firm received over 2,000 DSARs in a single day.
- Product sales data reporting involved jumping between questions such as 168, 7 and 19, highlighting complexity.
- The FCA’s affordability rules are described as 1.5 sides of regulation, versus around 10 pages of “true interpretation” used in practice.
- In some markets, lending volumes have reduced by 80–90% following regulatory and affordability changes.
- The government has spoken about cutting regulation by 25% across regulators.
- Industry feedback notes no FCA fee increase since 2014, despite growing requirements.
- TSB’s example involved issues going back 10 years that were only picked up recently.
- The motor finance redress scheme is referenced as going back to 2007.
- One member’s customer base is described as 100% vulnerable customers.
- That firm answers customer calls within one minute, with all call centres in the UK.
- FCA compensation expectations are described as £700 per case, compared to some CMC claims suggesting £19,000 for 3 or 4 agreements.
- It is suggested that some issues can take up to 15 years to be identified and remediated.
Key Discussion Points
- The cumulative burden and pace of regulatory change, and its disproportionate impact on smaller and specialist lenders.
- The operational and interpretive challenges of product sales data reporting and similar granular data submissions.
- Consumer duty’s impact on affordability expectations, market tightening and exclusion of some communities from credit.
- The deepening financial strain on already struggling customers, even where headline arrears levels appear stable.
- The surge in online-driven complaints, DSARs and “no-win, no-fee” style activity, and the pressure this places on operational capacity.
- The tension between outcomes-based, principles-based regulation and the need for clear, transparent standards and guidance.
- Questions over whether promised regulatory burden reductions (e.g. 25% cut) have materialised in financial services.
- The role of technology and AI in monitoring compliance, evidencing good outcomes and managing large volumes of regulatory data.
- How technology, recordings and data-rich oversight are reshaping the enforcement sector, including ethics, privacy and complaint dynamics.
- Ongoing reforms at FOS and their impact on CMC economics, complaint volumes and claims culture.
- The evolution of vulnerability management, including definitions, identification at scale and consistency of treatment across sectors.
- Future risks from large-scale regulatory data pools, including outlier-driven supervision, sub-prime targeting and potential “big brother” concerns.
Session 2 : Effectively using Data & Analytics
Key Take Aways
- Firms face increasing complexity in managing and interpreting large volumes of data across legacy systems, digital channels and third-party environments.
- Data quality, catalogue completeness and consistent definitions remain major barriers, especially for product sales data.
- Historical data is not always reliable for forecasting, given changing customer behaviour, new products and evolving regulatory expectations.
- Lenders need to become more data-savvy, with staff trained to understand new data types, behavioural indicators and AI outputs.
- Credit bureau and transactional data increasingly reveal early signs of stress, such as shifts in spending, reduced buffers and changes in shopping patterns.
- AI adoption is growing, but customers react negatively when AI-driven insights feel intrusive or “Big Brother-like.”
- Behavioural data and psychology are becoming core to collections strategies, especially in predicting engagement and tailoring channels.
- Product sales data implementation has been difficult due to unclear definitions, missing data, data quality challenges and differing interpretations across firms.
- Firms must integrate data into change management, ensuring future systems are designed for interoperability, measurement and regulatory reporting.
- Operational teams need systems that capture the right data automatically so frontline staff can focus on conversations, not manual recording.
- FCA outcomes testing requires firms to demonstrate not only operational improvements but also improved customer outcomes.
- Open banking remains widely used and is becoming business-as-usual, offering easier and more accurate affordability assessment than traditional statements.
Innovatation
- Using AI to detect behavioural indicators such as form-hovering, hesitation and navigation difficulty during digital journeys.
- Keystroke replication and automation to accelerate data analysis and reduce manual effort.
- AI-driven scorecards to route customers dynamically based on patterns rather than static rules.
- Behavioural prompts and nudges embedded into collection journeys, derived from data signals.
- Integrated models linking bank interaction history, DCA strategies and digital engagement to personalise collections.
- APIs embedded throughout change-management processes to ensure future data capture and measurement.
Key Statistics
- 200–300 people working for 18 months on migration and data-related transformation at a major bank.
- Some products require dual processing due to differences between legacy and new systems.
- 24 business areas involved in digitisation and decisioning transformation.
- Behavioural programme claims an uplift achievable in four days.
Key Discussion Points
- How firms choose which data to focus on amid overwhelming volumes.
- The challenge of creating consistent data definitions for product sales data.
- The impact of missing or unclear data on regulatory submissions and analytics.
- The growing importance of behavioural insights in collections decisioning.
- The tension between using AI for efficiency and maintaining customer trust.
- Integrating data across legacy environments, third-party DCAs and disparate systems.
- The need for data-driven change-management frameworks tied to KPIs and customer outcomes.
- Ensuring frontline staff capture data consistently while maintaining high-quality customer conversations.
- Future readiness: designing systems to support regulatory reporting, API connectivity and measurement.
- The shift from manual affordability assessments to open banking-driven insights.
- How firms evidence that digital changes improve customer outcomes, not just KPIs.
- Preparing for increased FCA data use, including thematic analysis of product sales data and new reporting.
Session 3 : Value of Communications
Key Take Aways
- Firms must deeply understand customer mindsets, especially stress behaviours, avoidance tendencies, and short-term thinking, to design effective communications.
- “Customer first” operating models, with roles dedicated to representing the customer voice, support clearer and more empathetic engagement.
- Written communication must use low reading ages, simple design and clear calls to action, reflecting modern expectations and reducing misunderstanding.
- Omni-channel strategies remain essential, with customers shifting channel preference during different stages of their financial journey.
- Telephony continues to play a critical role, especially for vulnerable customers and for detecting needs that digital cannot surface.
- AI can personalise content, adjust tone, tailor reading levels and recommend the most effective communication channel based on behavioural signals.
- Customer communication preferences can be both stated and inferred; firms must combine data with human judgement to determine true needs.
- AI and machine-learning models require continuous monitoring to avoid drift, bias and unintended outcomes, with human-in-the-loop models recommended.
- Increasing automation can free staff for more sensitive customer interactions, but requires strong controls and ongoing performance review.
- Regulation is shifting towards outcomes-based expectations; firms must evidence consumer understanding and fair outcomes across channels.
- Explainability in decisioning is essential, particularly as AI-assisted credit and collections processes expand.
- Measuring communication effectiveness requires behavioural metrics, customer actions, complaints, sentiment and channel-level data.
Innovatation
- AI-driven personalisation of tone, reading age and message style for each customer.
- Behavioural analytics highlighting hesitation, navigation patterns and disengagement points in digital journeys.
- GenAI optimisation (“GEO”) for marketing and acquisition, aligned to new search behaviours.
- Automated recommendation engines suggesting optimal contact time, channel and approach based on live customer data.
- Large-scale speech and call analytics for vulnerability detection and sentiment analysis.
- Integrated omni-channel data synchronisation enabling seamless movement between channels.
Key Statistics
- HMRC previously reported 300,000 customers receiving communication at one stage in a major digital shift.
- One firm reports 40% of its customers have at least one present vulnerability, with an average of three vulnerabilities.
- Klarna analysis showed younger customers (25–30) had lowest chatbot satisfaction, while those 31–35 had the highest.
- Call-centre communication reading level targeted at around age 11 for clarity.
Key Discussion Points
- How to identify and influence customer mindset during periods of financial stress.
- The limits of customer journey mapping when customers behave differently under different circumstances.
- Importance of low-friction omni-channel journeys with customer-driven channel switching.
- Balancing channel complexity with cost, operational capacity and customer expectations.
- Managing AI-driven personalisation ethically, avoiding bias and ensuring explainability.
- The evolution of channel preferences across a customer’s lifecycle and changing financial circumstances.
- How to infer communication preferences from historical behaviour rather than relying only on stated preferences.
- Ensuring transparency and auditability of AI-supported decisions under growing regulatory scrutiny.
- How to design communication journeys that still preserve human support at critical points.
- Using communications to gather actionable data for segmentation, personas and behavioural modelling.
- Ensuring customer understanding of key information, especially costs, product mechanics and outcomes.
- Preparing communication strategies for 2026, focusing on data-driven personalisation, AI literacy and clear value measurement.
Session 4 : Future of Technology in Credit & Collections
Key Take Aways
- Investment in technology and AI has accelerated across the credit and collections sector in 2025
- Organisations are shifting focus from “AI hype” to solving concrete business problems
- Foundational data quality and modern data infrastructure are now seen as essential enablers
- Legacy systems remain a barrier, but legacy policy and legacy thinking are often bigger blockers
- Generative AI is driving interest, but its value depends on strong context, governance and business alignment
- Human-in-the-loop decision-making remains critical and is unlikely to disappear
- Personalised journeys, personalised communications and dynamic context windows are emerging priorities
- Data security, model safety and clarity on how models use data are rising concerns
- The industry must prepare for AI-driven consumer behaviour, including automated consumer requests
- Fraud risk is increasing as criminals adopt AI more quickly than regulated firms
- Firms must plan for business continuity when AI platforms or cloud infrastructure fail
- The next stage of AI adoption will move from hype to demonstrable business value
Innovatation
- Use of dynamic context windows to tailor LLM outputs to customer, business and industry rules
- Embedding multiple small language models and large language models within platforms
- Personalised video communication using new generative media tools
- AI-driven triage for contact centres, reserving human agents for specialist and high-value cases
- Development of hyper-specific models built on industry-specific context
- Automated consumer-initiated interactions driven by AI personal finance tools
Key Statistics
- 85% average automation rate referenced by a vendor across client implementations
- 300 DSARs received by a firm in a previous example, with predictions of thousands driven by AI
- 70% potential contact-centre reduction discussed as a hypothetical business objective
- 5–10% expected error rates if humans were fully removed from certain AI-driven decisions
Key Discussion Points
- AI hype versus real business value and the need for problem-first design
- Foundational importance of modern data architecture before deploying AI
- Challenges integrating AI with legacy systems, processes and policy frameworks
- Security, data governance and misconceptions about “safe” versions of public AI tools
- Potential regulatory constraints on removing humans from decision-making
- The likelihood that customers will adopt AI automation faster than creditors
- Risks of AI-generated consumer complaints and mass automated requests
- Business continuity implications of AI or cloud outages
- Fraud amplification through AI tools
- The need for AI literacy and fluency across organisations
- Emerging personalisation technologies in collections communication
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