A interesting deep dive into the enforcement sector, the consultation and implications of the vulnerability and ability to pay standards from the Enforcement Conduct Board.
Some notes from the session below.
Key Take Aways
- ECB is introducing new enforcement standards with a vulnerability-first mindset that supports safer enforcement.
- Vulnerability is shifting from a binary approach to assessing “vulnerable to what”, replacing older checklist models.
- Enforcement may proceed where vulnerability is present if harms are assessed and it is safe and appropriate to continue.
- Higher identification of vulnerability is expected, but fewer cases should require intensive welfare support.
- Ability-to-pay and vulnerability standards need to operate as a coherent framework rather than standalone elements.
- Firms must objectively assess a person’s ability to pay, taking account of recognised income-and-expenditure assessments.
- Stakeholders emphasised the need for practical examples, scenarios, and guidance before implementation.
- Regulators increasingly expect evidence-based, outcome-focused compliance rather than narrative statements.
- Cross-sector data-sharing across utilities, finance, and local government is becoming more significant.
- Data-driven approaches to vulnerability are often viewed as more effective than vulnerability-first models alone.
- New technologies such as speech analytics, AI and agent-assist tools are helping identify vulnerability indicators.
- Alignment with the debt-advice sector and use of the Standard Financial Statement remains a debated issue.
Innovation
- Safe-by-design enforcement models.
- Use of speech analytics and AI to identify vulnerability.
- Cross-sector data-sharing with support services and utilities.
- Income-optimisation and ability-to-pay assessment tools.
- Use of body-worn cameras for quality assurance and evidencing interactions.
Key Statistics
- 52% of clients in major debt-advice organisations are identified as vulnerable.
- 36% of those experience mental-health-related vulnerability.
- Approximately 250,000 clients are making some form of debt repayment.
- Over 1 million individuals are recorded on cross-sector vulnerability registers.
- 87% of debt-advice sessions are now digital.
- Firms using speech analytics have seen a 10% uplift in vulnerability identification.
Key Discussion Points
- Defining vulnerability clearly and practically.
- Balancing vulnerability-first vs data-driven models.
- Proportionality of new standards for different-sized firms.
- Aligning ability-to-pay standards with vulnerability standards.
- The role of technology in early identification.
- Tension between statutory requirements and accreditation expectations.
- Need for examples and guidance to support adoption.
- Consistency and use of the Standard Financial Statement.
- What evidence regulators expect when assessing compliance.
- Barriers and opportunities in cross-sector data-sharing.
- Ensuring repayment arrangements are sustainable.
- Improving collaboration with the debt-advice sector.
Description
This discussion explored the ECB’s proposed new enforcement standards, focusing on vulnerability, ability to pay, safer enforcement processes, and alignment with wider regulatory expectations. Speakers examine operational challenges, cross-sector learning, data-sharing, evidence requirements, and the practical impact on firms, agents and debt-advice bodies. The session includes debate on implementation, technology use, and how standards can be applied consistently across enforcement.
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