Motor finance challenges
This is not the first time car finance arrangements have been the subject of one of our updates. Less than 6 months ago we said, “three motor finance firms are facing a class action in respect of overcharging…..the excessive interest claims are eye-wateringly large and if Courts follow the PPI ‘Plevin’ precedent, many more firms […]
Spotlight on directors
We are only a couple of weeks into 2024 and the year is already throwing up governance, risk and compliance challenges for individual directors and senior managers. The downside risk of falling asleep at the wheel, or knowingly acting recklessly, has been brought into focus by two high profile and expensive actions against individuals in […]
A challenging year
As we rapidly approach the end of what has been a challenging year for everyone involved in the financial services market, we continue to support our clients as they manage their way through the increased background of regulatory pressures. Consumer Duty being the ‘biggie’ to affect everyone during 2023 and with further implications in 2024 […]
Consumer Duty – can you defend your position?
When our prudential regulator calls out a potential conduct issue, while at the same time deferring to the conduct regulator, we should all recognise a problem is brewing! Within the formal record of the Financial Policy Committee meetings in September and October, the Bank of England highlights its concern about the increasing length of mortgage […]
Later Life lending – regulatory update
The FCA published the results of its multi-firm work on later life mortgage advertising and advice, which can be summarised as “action is needed to ensure good outcomes for later life borrowers”. However, surprisingly, some commentators have dismissed the urgency of any resulting action suggesting there is “nothing to see here” and that the FCA […]
Managing risk in loan portfolios
As risk consultants, with people that have lived through numerous previous recessions, we recognise the cyclical nature of the economy and the need to be prepared for whatever is thrown at us. We have been warning about the cost-of-living crisis, increasing debt to income ratios, payments shock for borrowers leaving fixed rate loans, increasing arrears […]
Car finance firms face legal threat
The phrase ‘that’s the tip of the iceberg’ is often overused, but not in the case of three motor finance firms facing a class action in respect of overcharging claims. First, the excessive interest claims are eye wateringly large and second, if Courts follow the PPI ‘Plevin’ precedent, many more firms will be targeted with […]
Stress tests should apply to all lenders!
The Bank of England recently announced that the major UK banks would be resilient to a severe stress scenario. Re-assuring news, especially considering that their stress scenario was more severe than the downturn during the global financial crisis and significantly more severe than current economic forecasts. PRA regulated banks are of course used to considering […]
FCA clampdown – a firm warning!
The FCA recently published its 2022/2023 annual report. Within the 200+ pages, there are many ‘golden nuggets’ of advice for existing authorised firms and individuals as well as those aspiring to such privileged positions. The report contains data showing it is getting tougher where it sees or predicts consumer harm. It notes that it cancelled […]