CSA Compliance Roundup - 14 May 2025

In this issue

• CSA meets Treasury Minister to discuss Debt Purchase & Collections
• CSA receives response to letter to the Justice Minister
• FCA changes reporting requirements for debt advice; advises of slowing pace for further reporting changes
• FCA appoints David Geale as Executive Director for Payments and Digital Finance
• FOS rise in complaints highlights regulatory pressure points for credit & collections sector
• UK Finance launches their Take Five to Stop Fraud campaign
• SRA outlines strategic priorities amid rising sector risks
• HCEOA advocates High Court route amid growing County Court backlogs
• New research links debt with sharp decline in Mental Health
• Consultations

CSA meets Treasury Minister to discuss Debt Purchase & Collections

Last week, Chris Leslie, Chief Executive of the Credit Services Association (CSA), met with Economic Secretary to the Treasury, Emma Reynolds MP, to discuss the debt collection and debt purchase sector. He provided the following update on the meeting in last week’s CSA News.

“CSA Chief Executive Chris Leslie met earlier this week with Emma Reynolds MP, Economic Secretary to the Treasury, together with her officials, to discuss several issues affecting debt purchase and collections. 

With the Financial Ombudsman Service (FOS) interpreting last year’s Supreme Court judgement in a manner which suggests that debt purchasers could hold liabilities for potential redress in unfair relationship cases - even if those unfair relationships were clearly the responsibility of the originating creditor - the CSA has sought to highlight the risks to credit markets, our sector and to consumers from such an approach.

Chris urged the Minister to help clarify that the Consumer Credit Act (CCA) does not and should not allow creditors to repudiate responsibilities for errors, given that the FOS interpretation could have lasting consequences for lender accountability. The Minister explained that there are plans to reform the CCA later in this Parliament and the CSA’s engagement in the detail is very welcome. 

The CSA also presented recommendations from the forthcoming CSA policy paper on FOS reform, as the Minister is leading a review of FOS due to conclude in the summer. The Minister was also urged to work with our sector in supporting public sector collections policy modernisation, as set out in the CSA’s ‘Keeping Pace’ policy discussion paper, published earlier this year”

CSA receives response to letter to the Justice Minister

We also heard back from the Justice Minister, Sarah Sackman MP, this week, after we wrote to her recently about several issues. We shared our concerns about the Civil Justice Council’s (CJC) recommendations for changes to the Pre-Action Protocol and, as was also clear from the response we received from the Civil Procedure Rules Committee, the Committee currently has a number of other priorities before it will get into the CJC’s recommendations. We also alerted the Minister to misuse of the data access rights in the courts, which she acknowledged and noted the Court’s powers to dismiss cases without merit. Finally, we also sought an update on plans to begin naming claimants in the Register of

Judgments, Orders and Fines. The Minister was unable to provide a timeframe, but noted that Registry Trust and HM Courts and Tribunals Service are working to implement the reform.”

FCA changes reporting requirements for debt advice; advises of slowing pace for further reporting changes

The Financial Conduct Authority (FCA) has announced a significant transformation in the way consumer credit data is collected and reported, with the current suite of reports set to be phased out and replaced by a more streamlined and targeted framework. This change is designed to enhance the quality and relevance of data submitted by firms engaged in regulated consumer credit activities. 

These reforms aim to improve the FCA’s supervisory capabilities and ensure that data collected is proportionate, meaningful, and aligned with the evolving credit landscape. The changes signal a shift towards greater transparency and accountability, particularly in how credit agreements are originated and managed over time. The updated requirements will also influence how annual fees are calculated and how firms demonstrate compliance, making it essential for CSA members to review their reporting processes and prepare for the transition.

CSA head of policy, Daniel Spenceley, commented on the announcement in last week’s CSA News:

“The FCA has published its policy statement on changes to regulatory reporting for debt advice and credit broking firms. Alongside that policy statement, it has given an interesting update on its plans for changing the consumer credit regulatory return for other firms. We held a workshop with the FCA and CSA members last year to discuss the FCA’s plans for changing regulatory reporting for debt collection and debt purchase, and we were expecting a consultation early this year – but in an update this week, the FCA has advised that it is now slowing down this work. It states it has made this decision “in order to lessen the burden on firms and allow us to consider the impact, and value, of this new return and the new consumer credit Product Sales Data returns”. We will continue to engage with the FCA on this work and will keep members updated as and when there are further developments.”

FCA to replace consumer credit data reports | FCA

FCA appoints David Geale as Executive Director for Payments and Digital Finance

The Financial Conduct Authority (FCA) has announced the appointment of David Geale as Executive Director for Payments and Digital Finance, in addition to his existing role as Managing Director of the Payment Systems Regulator (PSR). With a longstanding career in senior regulatory positions, Geale brings experience that is expected to support the FCA’s ongoing priorities around innovation, consumer protection, and the integrity of financial markets. His dual appointment signals a continued emphasis on aligning regulatory oversight with the rapid evolution of digital finance and payment technologies across the UK.

David Geale appointed executive director for payments and digital finance | FCA

FOS rise in complaints highlights regulatory pressure points for credit & collections sector

The Financial Ombudsman Service (FOS) received 141,846 new complaints in the second half of 2024—a 49% increase compared to the same period in 2023. The banking and credit sector accounted for the majority, with 109,155 complaints, up from 62,139 the previous year. Key areas of concern included disputes over credit affordability, motor finance commission arrangements, and banking fraud. A notable shift was the sharp rise in complaints submitted by professional representatives, which grew from 22% to 46% year-on-year. In response, the FOS has introduced a revised fee model for high-volume representatives, aimed at encouraging more robust and evidence-based submissions.

For CSA Members, these trends reflect intensifying scrutiny of creditworthiness assessments and broader conduct standards. Although the uphold rate fell slightly to 33%, the volume and nature of complaints suggest persistent concerns around fair treatment and responsible lending. The FOS has also indicated plans to modernise the redress framework in collaboration with HM Treasury and the Financial Conduct Authority. Against this backdrop, firms are advised to review their affordability checks, customer engagement practices, and complaint handling procedures to ensure alignment with evolving regulatory expectations and to mitigate potential reputational and operational risks.

Financial Ombudsman Service received over 140,000 complaints in the second half of 2024 – Financial Ombudsman service

Half-yearly complaints data: H2 2024 – Financial Ombudsman service

UK Finance launches their Take Five to Stop Fraud campaign

UK Finance’s latest “Take Five” campaign taps into the nation’s enthusiasm for football to deliver a timely and engaging message about fraud prevention. With financial fraud costing the UK over £3 million each day, the initiative encourages individuals to adopt straightforward, preventative actions to help identify and avoid scams. By drawing a parallel between the alertness required on the football pitch and the vigilance needed to safeguard personal and financial data, the campaign reinforces its core message: Stop, Challenge, Protect.

This initiative reflects a broader focus on consumer protection and the critical role of fraud awareness across all areas of engagement. Insights from the campaign—such as the relatively low number of people who question suspicious requests or seek advice from trusted sources—highlight opportunities for firms to enhance outcomes through targeted customer education and staff training. As fraudulent methods become increasingly sophisticated, aligning operational practices with public awareness efforts like Take Five can contribute to building greater trust and resilience within the financial services sector.

Take Five - To Stop Fraud

SRA outlines strategic priorities amid rising sector risks

The Solicitors Regulation Authority (SRA) has launched a consultation on its draft Business Plan and budget for 2025–2026, marking the final year of its current Corporate Strategy. The plan responds to a rapidly evolving legal landscape, with a notable rise in reports of solicitor misconduct, increasing complexity in investigations, and growing concerns around high-volume consumer claims. To address these challenges, the SRA proposes a significant expansion of its regulatory activities, including enhanced use of data and intelligence to identify risks earlier, a stronger focus on professional ethics, and reforms aimed at better safeguarding client money.

The closing date for responses to the consultation is 19 June 2025.SRA | SRA sets out expanded 2025/26 business plan to address rising risks in legal services

SRA | Business Plan and Budget 2025-26 | Solicitors Regulation Authority

HCEOA advocates High Court route amid growing County Court backlogs

The High Court Enforcement Officers Association (HCEOA), is highlighting the growing delays in County Court evictions and encouraging landlords to consider High Court enforcement as a more efficient alternative. Across England and Wales, landlords are facing significant backlogs where eviction processes can be delayed by a year or more, even after a Possession Order has been granted. 

These developments underscore the operational impact of court delays and the importance of understanding alternative enforcement routes. The initiative also signals a broader push for legislative reform, with the HCEOA and its partners gathering data to demonstrate the scale of the issue and advocate for a more streamlined legal process. While the use of High Court enforcement is framed as a last resort in cases of non-compliance with court orders, it presents a viable option for mitigating the effects of systemic delays within the County Court system.

Landlords urged to use High Court enforcement to tackle County Court eviction delays

New research links debt with sharp decline in Mental Health

Recent research from National Debtline, published by the Money Advice Trust to coincide with Mental Health Awareness Week, highlights a significant link between financial difficulty and declining mental health. The findings show that individuals in arrears on household bills are more than twice as likely to report very poor mental wellbeing compared to those not in debt—16% versus 6%, respectively. The impact is not limited to mental health alone; 13% of those struggling with debt also report experiencing very poor physical health. The data points to broader societal challenges, with younger adults and private renters emerging as particularly vulnerable groups.

These insights underscore the critical need to identify and respond to signs of vulnerability in customer interactions. The research suggests that financial stress can both result from and contribute to deteriorating health, affecting not only those in arrears but also individuals experiencing high levels of financial anxiety. As demand for mental health support continues to grow, the report calls for stronger integration between financial and mental health services. This approach may also inform best practice across the credit and collections sector, particularly in areas such as customer engagement, risk assessment, and support frameworks.

MAT | People in debt more than twice as likely to report very poor mental health, new research reveals

Consultations

The following are consultation papers that are currently open for responses and may be of relevance to some or all CSA members. 

If an industry response is warranted and you want to contribute, please contact CSA head of policy, Daniel Spenceley (daniel.spenceley@csa-uk.com). 

CP25/8: Data Decommissioning: Removing reporting and notification requirements
Closing Date: 14th May 2025

Review of Scotland’s statutory debt solutions
Closing Date: 4th June 2025

Improving the administration and enforcement of Council Tax in Wales
Closing Date: 23rd July 2025