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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

01-04-2016

Blog: Subscription traps: The responsible way to use Continuous Payment Authorities (CPAs)

Daniel Spenceley is CSA Compliance Manager.

 

Citizens Advice’s recent report on ‘subscription traps’ highlighted worrying issues with poor use of Continuous Payment Authorities (CPAs) by online retailers like Amazon, who came under fire last year for its Amazon Prime ‘trial’, which saw customers unknowingly tied into annual payments. It showed a lack of awareness amongst customers about what the payment mechanism is and how it works, with only 21% knowing the difference between a CPA and a direct debit because of things like unclear terms and conditions and pushy advertising ‘tricking’ people into signing up. 84% of those surveyed didn’t even realise they had agreed to a subscription and 36% had a request to cancel a CPA turned down or ignored.

 

The benefits of CPAs

There has been a lot of negativity around the use of CPAs in the past, particularly by payday loan providers who, under a CPA, could make repeated attempts at taking different amounts out of customers’ accounts at different times without having to get permission after the initial agreement. However, when consumer credit regulation came under the Financial Conduct Authority’s (FCA) jurisdiction, they took immediate steps to ensure CPAs were being used appropriately, introducing a number of rules specifically for the use of CPA in the payday lending sector.

 

Of course, when used responsibly, CPAs can be a good option for customers who need to make regular payments totalling a set amount over the short term without the hassle of having to repeatedly agree to payments they are already expecting. Unlike failed direct debits, customers do not incur charges if they do not have the funds when a firm tries to take a payment under a CPA, and they have the right to ask for payments to be cancelled at any time, no questions asked.

 

How CPAs are used in the debt collection sector

CPAs are used in the debt collection sector as a mechanism for taking pre-agreed consumer re-payments of debts. This is an effective way of ensuring that customers stay on track with repayments, helping them to clear debts as quickly and affordably as possible, without the fear of incurring charges if there are issues with the payment. This is done in the context of FCA regulation which requires firms to provide comprehensive information to customers about the CPA process, including their cancellation rights, as well as giving them the opportunity to consider the terms of the CPA before payment is taken, so that they are fully aware of what is going to happen.

 

Unlike a subscription that is renewed annually, which can easily be forgotten about as it is not as visible as a direct debit, making debt repayments using a CPA helps to resolve a short term issue. Once the full amount is repaid, the CPA is terminated.

 

Ensuring customer transparency around CPAs

FCA rules and guidance around the use of CPAs for regulated debt collection are focused on ensuring there is complete transparency between the debt collection agency and the customer. This is mutually beneficial because it means that customers are fully aware of the process and their rights but they are also encouraged to make the firm fully aware of any changes to their circumstances that would see them asking their bank to cancel future payments.

 

The Citizens Advice report also recommends that banks and card issuers provide training for their frontline staff on cancelling CPAs and ‘mystery shop’ them to ensure the correct procedure is being followed. Although it is difficult to replicate the ‘mystery shopper’ approach in the debt collection sector, the CSA will also help members by including questions on CPA usage as part of the next full revision of the Collector Accreditation Initiative (CAI); an online test which ensures collections professionals have the latest training and skills to go above and beyond compliance.

 

It is reassuring to see that our sector wasn’t mentioned in Citizens Advice’s report and we are confident that we are pushing best practice when it comes to the use of CPAs. We welcome the recommendations set out, which will ensure that all customers, including those of online retailers, are given the same level of transparency if and when CPAs are set up.