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+44 (0) 191 236 2709

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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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16-01-2015

DMC authorisation lapses - contact with "orphan" customers and unregistered trading names

The BBA has issued an update regarding the contact with the approximately 100 “orphaned” customers where the DMC permissions lapsed at 31 December 2014, and guidance on the approach for dealing with firms where the trading name that is being used in correspondence is not captured on the FCA Consumer Credit Register.  

Lapsed firms with “orphan accounts”
  • The FCA has confirmed that, for the nine firms with “orphan” accounts when their permission lapsed at 31 Dec 2014,
    • All impacted customers of these nine firms have been written to, either by the DMC or the FCA (where FCA did not receive assurances that contact had been made by the DMC)
    • The letter was to include key elements -
      • Clear position on regulatory status of the DMC
      • DMC no longer able to provide regulated debt management activity
      • Statement of debt outstanding
      • Availability of free debt advice as per the MAS leaflet
 
Some examples have come to light where all the trading names under which a DMC firm operates are not recorded on the Interim Permission Consumer Credit Register.  The note below is a summary of discussions with the FCA.
 
FCA position on portfolio transfers and lapses
  • DMCs that sell or transfer their portfolio, or where Interim Permission has lapsed were advised to write and advise customers and creditors.
  • DMCs that purchase from a third party, or transfer a portfolio within a Group, were also advised to write to customers and creditors of the change
  • This message was communicated by the FCA in webinars, workshops and roadshows as part of the AP01 authorisation engagement process
  • FCA see this communication as a requirement under Principle 6 and Principle 7.
  
If lenders have concerns about whether a firm or any trading name have interim permission, the facts need to be ascertained before any communications is sent to customers advising that their DMC is no longer authorised to manage their debt plans.

 
Lender considerations when portfolios sold or transferred

  • Obtain confirmation from the selling DMC as to what has happened (where possible)
     
  • Obtain confirmation from the acquiring DMC
  • When transaction was completed
  • Confirm that existing LOA remains operative, or whether new LOA are required.
  • When they wrote and advised customers
  • When they wrote and advised Creditors
 
  • Trading name not registered
    • If the trading name is not registered on the Consumer Credit Register, this should be highlighted to the DMC so that they can take immediate action to correct
    • Speaking to the FCA they have advised that firms with Interim permissions can do an online submission to amend the trading names on the register. This should only take a few days for the FCA to action, and therefore minimal delay for customer.
    • If the DMC no longer wish to use that trading name (and it is not recorded against them on the Credit Register), and a new case is submitted on these documents, my view is that they need to get a new LOA on the correct forms of a registered DMC firm/ trading name. (This aligns to the need to have clear communication with the customer, so that the customer knows who they are dealing with)
 
  • If a DMC sells their portfolio, the purchaser is likely to be assuming all rights under the contract. Unless the new DMC wants to change the LOA, the existing LOA would hold. The new DMC would need to provide evidence to the creditors that they have taken over the firm and therefore have authority to discuss the customers affairs. Any trading names that continue to be used need to be registered. If the trading name isn’t registered, the DMC need to do the online submission as mentioned above to correct the omission.
 
  • The advice from the FCA would imply that there should not be a situation where there is a significant customer impact if a trading name has not been registered, as this can be quickly remedied.  If delays and issues are occurring, can you please let me know as we would want to minimise impact on customers as these changes are not a result of any action that the customer has instigated.  
 
  • Lenders might decide to use discretion in exceptional circumstances, where they are satisfied that a known DMC has an authority to discuss a customers’ affairs, the DMC firm is on the Creditor Register with an Interim Permission status, however a trading name is in course of being updated.  

MAS Leaflet - what to do now if your debt management plan has stopped