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Complaints Procedure

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Making a complaint

We work hard to ensure our Members act within the rules set by the industry regulators.

Please click on the following link and read our Code of Practice. If you think a Member has broken the rules of this Code you can make a complaint by downloading our Complaints Form.

Before making a complaint we would encourage you to carry out the following activities:

 

  • Go to the Members Directory and check whether the company you wish to complain about is a Member of the CSA. If you are still unsure, feel free to contact us. If the company is a Member of the CSA then we are able to help you with your complaint.
  • On first instance, we recommend you contact the Member company to discuss any issues you have and enquire about their complaints process. If you are still dissatisfied with the outcome then you can review our Complaints Procedure.
  • If you believe that the Member has acted in breach of our Code of Practice and the complaint meets the necessary criteria, please complete, sign and return the Complaint Form to our registered address.

CSA Complaints Procedure

 How we deal with your complaint.

All complaints must be submitted in writing, with a signed complaint form. We require the form to be signed so that we, and our Member, have the requisite authorisation to share information.

The following is the sequence of events after the CSA receive a complaint form;

  • CSA receive a signed complaint form
  • CSA register the complaint and send a copy to the relevant Member company
  • The Member is given four weeks to respond directly to the complainant
  • CSA get a copy of the response from the Member company
  • CSA considers both positions and determines whether the Code of Practice has been breached
  • Appropriate action is taken (if required) to remedy the situation
  • If further information is required the CSA contact the relevant party (the complainant or the Member company).
  • After a full review, the CSA provides a formal response to the complainant

 

If you remain unhappy with the outcome of the complaint, you may have justification to escalate the matter to our our head of compliance, Claire Aynsley, claire.aynsley@csa-uk.com.

 

Please note: The CSA can only intervene when;

  • a Member company is in breach of the Code.
  • the company is a Member of the CSA (we cannot act when the complaint is about the client of a Member company, a bank or building society for example).
  • the information supplied by a Member company appears from the facts to be incorrect.

Methods of Contact

 

Address

Credit Services Association

Complaints Department

2 Esh Plaza

Sir Bobby Robson Way

Newcastle-upon-Tyne

NE13 9BA

 

Why the CSA need a signed copy of your complaint

 

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21-10-2016

Blog: Debt-to-income ratio and financial distress – what the debt collection sector can do

Leigh Berkley is President of the Credit Services Association (CSA) and Director of External Affairs & Development at Arrow Global.

 

In August, I attended the launch of the Financial Conduct Authority’s (FCA) latest Occasional Paper which asks the question: ‘Can we predict which consumer credit users will suffer financial distress?’ This has been published as part of the FCA’s investigations into approaches to assessing creditworthiness in the consumer credit market with a view to amending current guidance.

As debt collection sector professionals, we often deal with those that are in financial difficulty as a result of being unable to repay their outstanding debts. We therefore do our best to treat all customers sensitively. But, using data from the Wealth and Assets Survey, the Paper found that if we define financial distress just according to arrears, only 2% of individuals with outstanding consumer credit debt are suffering from it and this underestimates the problem. There are forms of financial distress which do not actually result in inability to make repayments but still have a negative impact on the person’s life and well-being with 16% of people saying debt is a heavy burden whether they have fallen behind on repayments or not because of subjective measures such as regularly running out of money or having to significantly cut back spending. We all need to work together to ensure that customers are being properly evaluated throughout their consumer credit journey.

 

Financial distress and well-being

The Wealth and Assets Survey (WAS) data analysed shows that those in financial distress (which, using broader subjective measures equates to 17% of people with outstanding consumer credit debt) have lower levels of life satisfaction and higher levels of anxiety, both of which have an impact on overall well-being and mental health. Financial distress may or may not affect the customer’s ability to repay outstanding debts.

 

Financial distress and borrowing/lending

The Paper acknowledges that use of consumer credit is by no means always an indicator of financial difficulty but can in fact be an indication of high income growth amongst young people who are borrowing now for future gain. It also acknowledges that it is not in creditors’ interests to lend to those who cannot afford to make the repayments and that means of assessing a customers’ creditworthiness are already robust and points out that only ‘high cost short term lenders’ such as pay day loans companies lend to those in high likelihood of default.

However, consumer credit lenders need more insight into which consumer credit users are most likely to suffer from financial distress before they can fully evaluate the impact upon them. Although use of consumer credit is widespread, the top 2.5% of those using it hold one third of the total debt and those with much of this debt in higher cost products are much more likely to suffer financial distress. The Paper gives us a greater understanding of the wider causes and implications of financial distress which could help both lenders and the debt collection sector assess customers’ circumstances more thoroughly.

 

Financial distress and ‘life events’

Losing your job or getting divorced, which lenders can’t predict at the time of selling a consumer credit product, are life events that could typically lead to financial distress. However, the report found that life events such as these happen equally amongst those who are in financial distress and those who are not.

 

Debt-to-income ratio

The Paper identified debt-to-income ratio (the proportion of a consumer’s gross income that is used to pay off debts including taxes, credit etc) as a much stronger indicator of someone’s potential for future financial distress. Those with the top 10% highest debt-to-income ratio hold a third of total consumer credit debt, have debt levels of more than two and a half month’s household income, tend to be younger on lower incomes, and are the most likely to suffer financial distress.

Although debt-to-income ratio can’t solely be used to determine an individual’s likelihood of experiencing financial distress, it does give us greater insight into what may make consumers more vulnerable to it which can inform how we deal with them to alleviate any unnecessary stress or anxiety.

 

Improving affordability assessments

The Paper’s findings indicate that debt-to-income ratio should be considered as part of affordability assessments for consumer credit products, particularly for younger individuals. This more in-depth look at customers’ personal circumstances is more reliable in predicting and preventing financial distress than looking at the individual’s overall levels of debt and number of credit products.

At the UK Credit & Collections Conference in September 2016, we held a fascinating panel discussion on vulnerability, mental health and debt which included Helen Barnard of the Joseph Rowntree Foundation who pointed out that we do not do enough to identify and support those on low incomes as vulnerable customers. This is something that we as an industry will be looking at addressing over the next 12 months.