COLLECTIONS CCR
IS EVERYONE YOU WORK WITH COMPLIANT TOO?
New regulations mean that credit lenders need to make sure that firms acting on their behalf are compliant too By Simon Brown
CREDIT lenders and motor dealers have been dealing with significant changes to the regulatory landscape over the past 18 months. This has posed a number of
challenges to the industry, not least the reality of dealing with making multiple changes to business operations, structures, and control frameworks over a relatively short timeframe.
A new challenge One particular challenge has been that the new Financial Conduct Authority regime for consumer credit requires firms to take ‘reasonable steps’ to ensure firms acting on their behalf comply with the regulatory regime. This means that motor-finance lenders can now be held accountable for the activities of their dealer network. Were misconduct to be found in a
motor dealer, the regulator would also ask questions of its associated lenders as to why they were not aware of the issues and what steps they had in place to spot conduct-risk issues. These requirements are complicated by the need to maintain effective commercial relationships in what
July 2015
remains a highly competitive marketplace. A prudent way forward would be to
implement a scheme, proactively monitoring and supporting dealer
compliance guidance together. Where a large network exists, it is
important to target limited resources to achieve an effective management of the conduct risks posed. A risk framework
By developing a customer-centric approach we can not only meet the demands of the regulator, but drive our business performance
compliance, which is proportionate and commercially focused, on the one hand, but provides a level of assurance meeting regulatory requirements on the other.
The three-lines model This would sit as the first line in the traditional three-lines model, blending relationship building and compliance support with a degree of information gathering, vigilance, and testing. This will inevitably mean a ‘boots on
the ground’ model, but very much geared to relationship building, support, and guidance. This support should be separated from the traditional business development roles in order to manage the conflict of providing sales and
www.CCRMagazine.co.uk
should be developed integrating management information to identify risks, as well as gathering information on current compliance via a survey or attestation process.
Looking forward The motor-finance world has embraced change proactively and has innovated solutions to new challenges. By developing a customer-centric approach we can not only meet the demands of the regulator, but drive our business performance. CCR
Simon Brown is head of compliance, risk and corporate services at Volkswagen Financial Services (UK) E-mail:
Simon.Brown@
vwfs.co.uk
35
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52