Weekly Blog by Philip King, CEO of the ICM - 'Measure for measure'

The Government has this week published its response to the BIS Select Committee's report on Debt Management published in March and it makes interesting reading.  The original report contained 23 recommendations and the government responds to each one in turn. The document can be found here and what pleases me is the measured and proportionate nature of the responses.

 

The timetable for the planned review of the regulatory framework, including the transfer of regulatory powers from the OFT to the FCA, is set out with the final transfer expected to take place by April 2014.  Having a clear timetable and plan including expected consultation dates is helpful.  The more interesting aspects, however, relate to payday loans and debt management companies.

On payday loans, the Government refers to the work it has been carrying out with the four main trade associations representing over 90% of the payday loan market to improve consumer protection in their codes of practice.  These improvements together with the OFT’s review investigating levels of compliance with the Consumer Credit Act are, in my view, the right approach before any more stringent measures are considered.  Furthermore, the codes include measures to address the issues of rollover loans, affordability assessment, and continuous payment authority, and the Government has undertaken to review how best to include high-cost credit transactions in credit files.

In summary, close engagement with the trade associations to introduce enhanced consumer protections into their codes of practice and their commitment to publish a common industry-wide Good Practice Customer Charter setting out in a clear, concise and user-friendly format what customers of payday and other short-term loans should expect from their lender is positive and encouraging.  One can never condone poor practice but I believe payday loans have their place in certain circumstances and meet a particular need.

With regard to Debt Management companies, the Government is working with stakeholders to develop a Protocol of best practice for debt management plans which will cover transparency of fees and costs (particularly where they are upfront), misleading advertising, and safeguarding client accounts.  Again, in my view, working with the industry and trade bodies makes absolute sense before considering legislation and heavier regulation.

 
It's worth also noting that – in both cases – the approach being proposed will deliver faster results than would be achieved by the introduction of legislation.  Finally, as an aside, I have to mention again my particular soapbox that Debt Management Plans should be reported in the insolvency statistics so that the published numbers are a true representation of personal insolvency levels.

Weekly Blog by Philip King, CEO of the ICM - 'Joined up thinking benefits customer'

I recently experienced, at close hand, the efforts of the police, local authorities, and other agencies attempting to work together to protect a vulnerable child. What it demonstrated to me is that acting independently creates frustration for all those involved or affected, prevents the best outcome being achieved and, indeed, stands in the way of getting the required result.

The same could be said of business. In far too many businesses we hear about the 'them and us' attitude that exists between sales and credit departments and how neither party is at fault when something goes wrong.

Take for example my own experience last week when I checked into a hotel ahead of the ICM Regional Roadshow in Sheffield. It was late and I was tired. I took the lift to the fourth floor only to find that the key card wouldn't open the door to room 411 (a not unusual occurrence in my experience) so I returned to reception and had the key card re-coded. The new key worked perfectly but as I stepped into 'my' room I realised from the bags on the bed and the clothes on the floor that somebody had got there first.

I returned to reception and was moved to a new room that was mercifully vacant. On my third visit to the Reception desk, I asked the very pleasant young lady why she didn't feel the need to apologise for the inconvenience I had been caused. Since the card coding machine malfunction wasn't her fault, and someone else had made the error that resulted in me being booked into an already occupied room, it was clear - in her mind at least - that there was nothing for her to apologise for!

Wherever we sit in an organisation, but especially as credit professionals, when we communicate with customers, suppliers or any other stakeholder, how we respond reflects on our business and how it is viewed. As Glen Bullivant reminded us at the Sheffield Roadshow last week, credit management - whether we like it or not - is customer service because we face the customer, we talk to the customer, and we manage the customer. Doing it well, and working effectively with all other parts of the business, is just one way in which we add real value. I'm reminded that someone once said: 'There's no pleasure in knowing the hole is in the other end of the boat'.

Oh, and if you were in room 411 at the Park Inn, Sheffield last Wednesday, you had a very lucky escape!