End of an era

So today marks my last day as a partner at TLT LLP. It has been an incredible seven years at the firm and we’ve achieved so much including:

– Winning Best Law Firm at the Car Finance Awards for four consecutive years 🚗 🏆
– Advising on some of the most interesting and challenging issues facing consumer, motor and mortgage finance providers ✍️ 💭
– Building strong and long standing relationships with our fabulous clients and trade associations 💪

It has been a real privilege to work with my colleagues both past and present. And it’s fair to say that I’ve picked up some lifelong friends along the way. There have been a lot of laughs too. So perhaps more of an ‘à bientôt’ than a ‘goodbye’.

I am, however, very excited to start my new role at Walker Morris LLP on 17 April 2023. So after a couple of weeks of fresh air, time with the family, walks on the beach and some delicious food and beverages, I’ll be back talking all things consumer, motor and mortgage!

FCA Credit Information Review

On 27 June 2019, the Financial Conduct Authority (FCA) launched its market study into the credit information market. It’s been launched because of the FCA’s concerns about the coverage and quality of credit information, the effectiveness of competition between credit reference agencies and the extent of consumer engagement.

The FCA’s aim is to get a better understanding of how the credit information market now works and how it may develop in the future by making it work more effectively for credit information user and consumers (where appropriate). 

The market study will focus on: 

  • the purpose, quality and accessibility of credit information
  • market structure, business models and competition
  • consumers’ engagement and understanding of credit information and how it impacts their behaviour

The FCA’s market study is not unsurprising.  Consumers are becoming much more aware of their credit report and rating (with a little help from comedian Marcus Brigstocke) and how this affects their ability to obtain credit.  A simple search of the Financial Ombudsman Service’s decision for May 2019 reports 324 decisions for consumers complaining about their credit reports. 

The FCA will report on its preliminary conclusions in Spring 2020 including, if appropriate, a discussion of potential remedies. 

https://www.fca.org.uk/news/press-releases/fca-launches-review-credit-information-market

The Financial Ombudsman Service Annual Review

On 15 May 2019, the Financial Ombudsman Service (FOS) published its annual review 2018/2019.  FOS reported (among other complaints) an 89% rise in complaints about consumer credit.

The high-cost short-term lending (HCSTL) sector remains on FOS’s radar.  It continues to hear from customers, who it says, have had trouble after being lent money and who’ve been left to struggle with unsustainable and persistent debt.  

FOS is concerned that businesses are still failing to assess a customer’s affordability and aren’t learning enough from the complaints its resolved.  To help businesses, FOS is publishing its decisions (https://www.ombudsman-decisions.org.uk) setting out its thinking on these types of complaints. Of particular note, is complaints arising out of loans taken out a long time ago. FOS says it’s taking the time to explain to lenders the questions they should ask before telling customers it’s too late to complain.

Given the Financial Conduct Authority’s recent interventions and FOS’s concerns, the HCSTL sector remains high on the agenda for now.

The Annual Review: https://annualreview.financial-ombudsman.org.uk