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The Credit Services Association (CSA)
Blog: CSA Annual Report 2017: Why it is more important than ever that debt collection agencies join their trade body
John Ricketts is President of the Credit Services Association.
Upon taking over as President of the Credit Services Association (CSA) at the beginning of 2017, I was struck by how far the organisation has come over the last few years. Since then it has become really obvious to me that being part of a trade body brings so many benefits to a company in the debt collection and debt purchase sector. Fundamentally, it provides a Code of Practice that fills the gaps in a regulator’s rule book and defines the way members should actually behave. It also builds trust with clients and consumers and is a much-respected badge of ‘respectability’ that is a pre-requisite of almost every client tender.
As the industry continues to change and evolve, we as a trade body must also continually re-understand what our members want and need us to do. I am pleased to report that we are shortly about to embark on a CSA membership survey, carried out by Investors in Customers, which will ensure that we understand what members want of their trade body.
In the meantime, here is an overview of what we have achieved as a trade body on behalf of our members and their customers/stakeholders in 2017:
The main focus of the Association is to lobby government or government bodies on policy and matters of law which will impact member businesses. This year we have liaised with a variety of key regulators and government departments either directly or indirectly. These included: HM Treasury, BEIS, the Financial Conduct Authority (FCA), Ofcom, Ofwat, Ofgem, the UK Regulators Network (UKRN), the Information Commissioner’s Office (ICO) and the Ministry of Justice (MoJ) amongst others.
The Association’s experienced professionals, including Head Office staff and Board, have worked hard to research, review, comment on, gain views from members and respond to an ever-increasing level of consultations from almost all sources. More specifically, the bridge created with the FCA has helped us to continue to communicate quickly and effectively on members’ behalf in a way that would be simply impractical at an individual level. We have been able to share what the FCA expects, which has been especially important as we enter the ‘supervision’ stage of authorisation, and in our understanding and interpretation of CONC.
Members will also be preparing for the new Senior Managers and Certification Regime which our compliance team have worked tirelessly to ready members for, in the form of dedicated events and webinars, and guidance documents to help with this important stage in the regulatory process. Eric Bash from Ofcom attended the 2017 Members’ Meeting and AGM to present Ofcom’s policy of persistent misuse of electronic communications, which came into force on 1 March 2017. Following the meeting the Association released a guidance document and Eric produced an insight into the statement following a number of questions posed by members which were unanswered at the February Meeting.
I attended along with CSA CEO, Peter Wallwork, a meeting at 10 Downing Street to discuss the Debt and Mental Health Evidence Forms (D&MHEF) where on behalf of the Association we welcomed efforts to remove the cost to the individual for the completion of the form. There was general agreement that if and when the form is considered necessary, any cost should not be borne by the customer. It was a positive start to the dialogue, and although there are opposing views, we fully support the Government’s ambition, and the ambition of the Minister, to continue to support the most vulnerable in society to ultimately becoming debt free.
General Data Protection Regulation (GDPR) and the Data Protection Act 2018
We continue to inform, guide and offer insight to members in this area ahead of May 2018. Leigh Berkley is now carrying on the work that our Chief Executive Peter Wallwork started on the board of the Federation of European National Collections Associations (FENCA), to put in place a code for debt collection within the GDPR and we should see some clear benefits from that work before the regulation goes live.
We are always exploring ways to further enhance the benefits of membership through introducing new initiatives or by improving existing member-exclusive services. Members also have access to a specially negotiated professional indemnity scheme through UKGlobal and access to HR, legal and health and safety information from experts at Croner.
We announced in 2017 that after working closely with Royal Mail CSA members could receive a discount rate if they test new mail applications through the Test & Innovate Scheme (TIS). The TIS was launched for the collections industry in August 2017 and acts as an incentive for firms to try new ideas and methods within their mailing activity. We were also very recently pleased to announce that this scheme has now been extended until 31 December 2018 having previously only been available until 31 January 2018.
We have also agreed an Exclusive Framework Agreement for members from cash collection services supplier, Paypoint. The framework offers four entry levels, designed to meet a diverse range of member business needs.
Revised CSA Code of Practice
On 5 July 2017 the Credit Services Association hosted an event at the House of Commons to launch a new revised version of the CSA Code of Practice. This updated Code, implemented from 4 January 2018, demonstrates the Association’s continued commitment to reflecting new developments within debt collection, as well as reinforcing the importance of best practice and to driving high standards. As well as outlining expectations regarding areas such as business set-up, the fair treatment of customers and staff training, the new code now also addresses member firms who find themselves falling outside of the FCA consumer credit regime due to the specialist collection services they provide.
The launch event enabled us to highlight the importance of the Code to senior representatives from debt advice charities, regulators, MPs and the press, and helped to further increase the recognition and awareness of the how the Code can serve those working with debt collection.
Learning & Development
Our range of learning and development qualifications continue to play an important part in assisting both members and non-members in meeting the demands of this ever-evolving and challenging industry. Our established Level 3 and Level 5 Diplomas offer dedicated qualifications specifically designed for those working within the debt collection industry. The ever-popular Collector Accreditation Initiative (CAI) enables companies to demonstrate their commitment to excellence through an affordable and flexible online service. Our newer product, introduced in late 2016 and linked to this, CSA Compliance Essentials, added another element of learning to all areas within an organisation and not just those on the collections floor.
I was delighted to see the Association accepted on the Register for Apprenticeship Training Providers (RoATP) in March 2017. As a Main Provider, the CSA now delivers apprenticeship training to employers, specialising in debt collection, compliance and leadership and management. What this means for members is that by choosing the CSA to deliver apprenticeship training they will receive the best quality standards in the industry plus the support needed as a levy-paying employer.
We recently welcomed the first of our apprenticeship cohorts as workshops began for the Level 3 Advanced Credit Control/Specialist Collections and Level 6 Senior Compliance Risk Specialist and we look forward to this developing throughout 2018.
Fiona Macaskill’s Learning and Development team were also recognised when they were shortlisted for Training Provider of the Year at the 2017 Collections & Customer Services Awards. Although we were not successful in picking up the award, our presence on the shortlist is in recognition of the Association’s commitment to delivering, and developing, first-class qualifications to the industry.
Debt Pre-Action Protocol (PAP)
In March 2017 the final version of the Pre-Action Protocol (PAP) for debt claims was published, and with it came the news that it would come into effect on 1 October 2017 – leaving creditors and claimants around six months to prepare. The CSA was one of the first to push for a formal consultation on PAP, and for over two years had been engaging with the MoJ during this long process. During this time, my predecessor Leigh Berkley sat on the sub-committee negotiating the PAP which aimed to encourage early engagement and communication between the parties, including early exchange of sufficient information to help clarify whether there are any issues in dispute.
Further information about PAP was prepared by the CSA in the form of a resource document and a webinar was delivered where attendees were able to submit questions during the live session.
Our close contact with this sector continues and we were encouraged when offered a seat on the Fairness Meeting panel at the Cabinet Office regarding the Standard Financial Statement (SFS) and how it fits in to debt collection. Peter Wallwork CEO and Leigh Berkley, CSA Board Director represented the Association and welcomed the launch to help create a clearer picture of an individual’s financial position and enable a fairer, faster resolution for resolving customer debts. SFS is now in place and we are encouraging members to register as users.
UK Credit and Collections Conference
This years’ UK Credit & Collections Conference (UKCCC) as always, was a packed programme including a keynote from Jo Pedder from the ICO and Philip Salter of the FCA. We also saw sessions revolving around the main themes of technology and innovation. Many congratulations to those who were recognised at our Gala Dinner Awards, including former CSA Board Member Jacky Cooper, who received an Honorary Membership for her contribution and commitment to the Association.
I was delighted to see the 2016 UKCCC win Conference of the Year at the Trade Association Forum’s (TAF) Best Practice Awards 2017. The event was recognised for utilising innovative technology and delivering relevant and informative content to delegates.
I look forward to welcoming returning delegates, as well as those who are attending for the first time, at the newly revamped event as we move to Stratford-upon -Avon in September 2018.
New Supplier Membership
In late 2017 we launched a new category of the Intermediary class of CSA membership - Supplier Membership. Allowing suppliers to the industry into the membership will bring additional benefits to current members, initially by introducing a new “supplier directory”, providing easier access to suppliers.
Businesses who qualify and supply services and products to the collections, debt sale and purchase industry receive the advantages that comes with membership, plus additional benefits which exposes your business directly to over 300 CSA members.
At the end of 2017 the CSA’s position as the “voice of the collections industry” was called into play when the Association and a selection of members came under the spotlight from the national press. One attempted to predict the next financial crash and the drivers for that, while another focused on what areas are under scrutiny from the FCA. It was therefore pleasing to see us avoid a story we think could have been wrongly detrimental to the industry’s reputation (of which we have worked hard to build over the years). Through successful communication and collaboration with all those involved, the resultant story brought some calm to the storm the journalist may have been trying to create.
As I began my presidency I wanted to build on our position as an organisation for the members, with even more benefits of membership, whilst retaining our consumer focus. I also want to encourage members to continue to promote and support the CSA Code of Practice as the common denominator for debt collection best practice in a multi regulatory environment. I want us to look to the future, and we have some exciting times ahead and plenty to do. Our aim is that the CSA will continue to keep pace with even our most ambitious members – large and small – and continue to lead the charge in demonstrating the professionalism of this industry. I hope that everything we have achieved this year demonstrates the importance of CSA membership and look forward to welcoming new members to the Association in 2018.