RE: Selling8 Sep 2020 08:36
Cavendish3 - Read in full and learn.
The FCA’s Executive Director of Supervision gave a speech at the Credit Summit, which took place on 21 March 2019, entitled “What can the consumer credit sector expect from the FCA?” .
The speech reiterated much of what was said in the High Cost Credit portfolio strategy letter issued on 6 March 2019. And in his speech the Executive Director of Supervision said:
“Over the last few years we have seen a dramatic increase in the use of guarantor loans by consumers. Balances on guarantor loans are fast approaching £1 billion and these have more than doubled since 2016.
While these products provide an opportunity for those with thin credit files - poor or limited credit history - we do have concerns. Concerns about affordability. Recent work we have done in this area showed that many guarantors are making at least 1 payment and the proportion of guarantors making these payments is growing.
There is also growing anecdotal evidence that guarantors may not understand how likely it is that they will be called upon to make a payment. Our work will therefore focus on affordability and on understanding whether potential guarantors have enough information to understand the likelihood and implications of the guarantee being enforced.
We have already amended certain rules to ensure that the protections they provide to borrowers also extend to guarantors, for example rules requiring forbearance, pre-contractual explanations and fair treatment. In assessing creditworthiness, we have clarified that firms must undertake a reasonable assessment of the potential for the guarantor’s commitment to have a significant adverse impact on their financial situation.
And if the guarantor is called upon, we have published guidance on our view of what constitutes ‘enforcement’ of the guarantee under the CCA – in practice this means we expect firms to provide guarantors with adequate notice before exercising a Continuous Payment Authority (CPA).
There are also questions over the level of interest rates charged on these products considering that these guarantors are deemed to be credit worthy, we will therefore be considering this and the business models of these firms”.