In Focus Consumer Credit
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arrears, but further discretion for money advisers to exclude other
forms of debt would increase take-up. l Accept reasonably up-to-date balances already held by money advisers – at present, it is required that advisers verbally confirm the balance of each debt included in a DPP with the creditor, taking note of the time of the telephone call and the name and department of the person spoken to. This clearly places a heavy burden onto
money advisers. Some policies mean that balances can
only be given in writing, which elongates the process and can often result in further delays for the client. Creditors are also asked by the AiB to
confirm the balance when a DPP is approved, which means the previous process is an unnecessary hurdle. l Extend the six-week interim intimation period to six months – it can often take longer than the present six-week intimation period to see an adviser, get finances together and acquire balances, on top of the 21 days given for a creditor to respond to a DAS application. This is especially the case when a DAS is
rejected by a creditor. We recommend that the six-week intimation period be extended to six months.
Sustainability Also, in terms of the sustainability of plans, we would recommend certain further key considerations:
l Remove the ability to reinstate interest and charges retrospectively if a DPP fails – those entering DAS risk an exacerbated financial situation, should lack of stability mean their DPP fails. This is because, if a client experiences
crisis and is unable to request a payment break, causing the DPP to fail, interest and charges are added retrospectively. This can cause further anxiety and distress
to a client. Although payment holidays exist, those requiring them are often not in the position to request one. However, if a Debt Management Plan fails, interest and charges are not added retrospectively.
l Improve client experience where a debt is reassigned – clients are expected to deal with correspondence from creditors themselves, informing money advisers of any changes that need to be made. Details of the DPP are not commonly
passed to a new creditor, and, if a client does not inform their adviser of the change, debts can often get collected – despite a statutory agreement to repay being in place. For those suffering from vulnerability,
such as mental ill-health, it is unreasonable to expect them to refer communication on to money advisers. We recommend that the creditor should
At present, it is required that advisers verbally confirm the balance of each debt included in a DPP with the creditor, taking note of the time of the telephone call and the name and department of the person spoken to. This places a heavy burden on money advisers
have to update the details of the DPP and should stop debts within a DPP being sold to a third-party. l There needs to be greater awareness built around DAS – there is a lack of awareness about DAS within Scotland and, therefore, there have been instances where DAS protections are not abided by. There needs to be better communication
between DAS-approved money advisers and creditors. This may include ensuring credit contact details on the DAS portal are up to date.
Conclusion DAS is leading the way in the UK with its protections, yet, with these changes, increasing flexibility and sustainability, DAS will be able to set the pace ahead of the introduction of an extended breathing- space scheme for England and Wales. CCR
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www.CCRMagazine.co.uk
November 2017
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