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Credit Services Association

2 Esh Plaza

Sir Bobby Robson Way

Great Park

Newcastle Upon Tyne

NE13 9BA

Additional Sections

Complaints Procedure

Useful Links

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

 

Top

10-08-2017

Blog: FCA Mission 2017/18: Setting the tone for consumer credit firms’ culture

Charley Taggart is a CSA Board Director and General Counsel at Cabot Credit Management.

 

The Financial Conduct Authority (FCA) has published its Mission and Business Plan for 2017/18 following consultation with a wide range of stakeholders. The ‘headline’ for the national media was a ‘considerable focus’ on personal debt beyond just specific areas such as payday lending, which has already been capped (see BBC news article here).

Both the FCA’s Chief Executive Andrew Bailey and the Bank of England have raised concerns over big increases in ‘high cost’ consumer borrowing and personal debt in the last year and, with the uncertainty of Brexit, concerns over consumers’ financial future and the sustainability of our financial markets are in the spotlight.

Ultimately, the FCA’s mission is to: ‘serve the public interest, and to add public value through [its] contribution to society’ and a key objective is ensuring consumer protection. This is not a new concept for the regulator but is a reminder to us all that putting the consumers’ interests first is no longer a ‘nice to have’.

 

So what does this mean for the debt collection and purchase sector?

We welcome greater transparency from the consumer credit regulator on how it sets its priorities and makes/enforces its regulatory decisions and the fact that the FCA is committed to involving and engaging with regulated firms more.

Debt collection agencies may not always have had the greatest reputation amongst consumers but our commercial goal has also always been about contributing to society by resolving outstanding issues for the mutual benefit of all those involved and the wider economy. Clearly, it is not commercially or socially beneficial to do this in a way that has a detrimental impact on customers.

When it comes to high risk lending, it is important that we work to streamline the customer journey and create a code on data sharing in order to open lines of communication so that we can share experiences of customers who end up in financial difficulty with lenders and provide insight into what went wrong. We also need lenders to share customer insight with us.

July has been a busy month for regulatory publications requiring our attention, the FCA has published several consultation papers, in addition to setting out its agenda and priorities for consumer credit.

The long awaited Consultation Paper on a new rule for staff incentives, remuneration and performance management in consumer credit was published on 4 July 2017 (CP17/20) and provides examples of good and poor practice the FCA has observed. CSA members should use these examples to assess whether their own performance management and remuneration frameworks meet the regulatory expectations.

The equally long awaited Consultation Paper on extending the Senior Managers and Certification Regime to all FCA firms was published on 26 July 2017 (CP17/25). All CSA members who are regulated by the FCA will be impacted by this regime and will need to ensure their Senior Managers and HR departments are aware of the coming changes.

They also published a Consultation Paper on assessing creditworthiness in consumer credit (CP17/27). This useful consultation will be of particular interest to consumer credit lenders but should be taken into account throughout the debt collection and purchase sector when considering proportionate and appropriate ways to ensure repayment plans are affordable and sustainable for consumers.

Any CSA members who would like to provide their thoughts or feedback on any of the Consultation Papers can provide their response to the Compliance and Regulatory Affairs team by contacting Daniel Spenceley on daniel.spenceley@csa-uk.com or Claire Aynsley on claire.aynsley@csa-uk.com.

The FCA’s focus and priorities in consumer credit continue to centre around high cost lending, referring in particular to unarranged overdrafts, rent-to-own, home collected credit and catalogue credit sectors. The FCA has stated they will be developing tailored solutions for the issues they have identified in these sectors and will consult on these in Spring 2018.

They have also set out their intentions to develop their understanding and motor finance products and to assess whether they cause harm to consumers. Areas of key focus for the FCA in the motor finance sector are:

  • Affordable lending
  • Management of conflicts of interest arising from commission arrangements
  • Clear and transparent information provided to consumers
  • Risk of asset devaluation

 

Creating a regulatory culture

In the past, embedding a regulatory culture throughout a business may have meant in some businesses, a ‘tick box’ approach, but it now means ensuring that our values are aligned with that of the regulator and it is useful to have greater clarity on what the FCA is trying to achieve and for what purpose.

In order to address concerns over high risk borrowing during uncertain financial times, we need to focus on sustainability.

As the BBC article mentioned above highlights, consumer credit lending is still less than 10% of all lending by UK banks to household borrowers but the potential consumer and commercial harm of debts such as unarranged overdrafts if we are hit by a big economic downturn is enough to make it a priority for the FCA.

When we put consumers and their interests first, the solutions we develop actually make more commercial sense.

The CSA’s UK Credit & Collections Conference in September 2017 will include a focus on collections culture in the light of the FCA’s new mission.