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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

 

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13-09-2016

Blog: The Standards of Lending Practice: Putting the customer first

David Pickering Lending Standards Board

David Pickering is Compliance Director and soon to be interim Chief Executive (from 1 October 2016) of the Lending Standards Board, which promotes fair lending by overseeing Registered Firms’ adherence to the Standards of Lending Practice. He and some of his colleagues will be attending and exhibiting at the Credit Services Association’s UK Credit & Collections Conference #ukccc on 15 September 2016.

 

The Lending Standards Board (LSB) and the wider industry had grown accustomed to the structure of the Lending Code, with its focus on detailed provisions and because of the value it added to financial services firms before the Financial Conduct Authority (FCA) introduced the Consumer Credit Sourcebook (CONC). Professor Russel Griggs’ independent report on the Lending Code last year, while highlighting its positive aspects, concluded that change was necessary if a Code was to have relevance when co-existing alongside the statutory regime.

Putting the customer first

We wanted to put the customer at the heart of lending practice to help firms truly embed a ‘customer first culture’. By having the customer as our ultimate reference point and then constructing a set of standards and principles around this, the new Standards of Lending Practice provides firms with greater flexibility to innovate and use their business models to achieve good customer outcomes.

From static provisions to evolving outcomes

Moving from provisions to outcomes and principles, underpinned by an oversight model that is forward looking and proactive, has caused a mindset shift, which has enabled us to broaden our thinking in terms of what can be achieved through the new regime and how voluntary self-regulation can help firms to achieve the right outcomes for their customers.

Unlike the Lending Code which was a static document subject to three yearly review, the Standards will be much more dynamic and continue to evolve. As the pace of technological advancements in the industry increase we need to ensure that the Standards keep track and, where possible, set the agenda for firms in terms of effective and pragmatic consumer protection.

We believe that the Standards and revised monitoring regime will benefit both firms and customers. Firms will see a much more efficient alignment between our work and that of the FCA, which will be truly complementary. For customers, they will know that we will retain our independence and will continue to challenge firms, holding them to account if they fall short of the expected standards, but not burdening firms with a costly and onerous monitoring regime that does not reflect current and emerging risks.

Good practice in the debt collection sector

We have seen a lot of good practice from debt collection firms who are becoming increasingly proactive in their approach to helping customers in financial difficulty and looking at ways to increase customer engagement and ensure that repayment plans are affordable and customers are able to maintain them. The overriding principle for managing customers in financial difficulty is that firms should know their customers in order to ensure that they receive the right outcome; if the best solution is a repayment plan, then a firm needs to obtain sufficient information to make sure an affordable plan is set and that this is in the customer’s best interests.  One area which we are regularly asked for is our view on how firms should approach the affordability assessments. We will shortly be publishing research we have undertaken in this area which we hope Firms will find helpful. 

Lending in the digital age

We’re also currently undertaking research focusing on developments within digital across the wider industry. This is an area which we know is a major challenge for firms and particularly for the debt collection sector. Credit Services Association (CSA) members, by virtue of their work, are at the back end of the customer journey and which has traditionally been focused on engaging with the customer on a one-to-one basis. When, for example, a vulnerable customer finds themselves in financial difficulty, there is a need for a firm to speak to the person so that they can fully understand their circumstances but the challenge is that the customer may not want, or may not be able to cope, with this kind of interaction. At the moment, the Standards of Lending Practice are channel neutral but we would like to provide something help inform Firm’s thinking on what ‘good’ looks like when a customer chooses to engage via a digital channel.

Sharing good practice

We are about to publish a series of documents to support the Standards called Information for Practitioners, these are non-binding examples of good practice and ideas which Firms may wish to take into consideration when developing their approach to adhering to the Standards and achieving the right customer outcome. The Information for Practitioners is owned by the LSB and as we conduct our research into emerging areas, we’ll update these documents to reflect further developments.

Reassuring the customer

In conjunction with the industry, we have developed a simple one-page document which sets out, at a high level, both the customer’s and the firm’s responsibilities under the credit agreement. In due course we will also develop a similar document which is more closely tailored to the debt collection world. We’re increasingly seeing firms across the spectrum wanting to draw attention to the fact that they are signed up to the Standards of Lending Practice. In response to this we’re developing a logo which firms can include on websites and literature, should they wish to do so.

 

The ‘Standards of Lending Practice’ have a key role to play in taking the industry forward and we look forward to talking to collections professionals, creditors and others at the UK Credit & Collections Conference on 15 September 2016 about how we can all work together on continuous improvement of customer outcomes.