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In Focus Risk


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members in all of these debates. Sometimes that is about being a loud


voice, but more often it has to be listening to those concerns. That is the challenge and so I am delighted


to have recently taken up the role of chief executive at the BCCA, representing alternative lenders and those firms offering third-party cheque-cashing services.


Formerly known as It is many years since we changed our name, initially to the British Cheque & Credit Association and then, more recently, to just the BCCA. However, we still receive post addressed to the British Cheque Cashers Association. In an age when branding is important, we politely correct this and talk about our wider membership, but it is true that we have continued to represent the third-party cheque cashers. It continues to be a product that we


represent. The cheque survives as a payment method still preferred by some, and there remains the opportunity to provide a service that meets a real need. The ability to access the funds from that cheque allows the customer to pay that bill or meet that other household expense. Many of our members have moved into


new areas over the years. It was only a short journey from cheque cashing into payday advances. Members brought forward their customer’s pay date by just a few days, in order to meet an unexpected expense. From what I have already seen in my


time as chief executive, that innovation continues. Technology is being used in the traditional high-street stores to improve customer service and adapt the products. Our online members are also seeking to provide new channels of access. That is not to say that we necessarily


agree with those that claim that everyone is going online for their borrowing. There is plenty of research, including the work of the Competition and Markets Authority, showing us that a proportion of the public feel more comfortable with visiting the high-street lenders. As an association, we are keen to see a diverse market that meets our customers’


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We are a channel of communication with the regulator, but, just as importantly, we help in the sharing of information amongst the membership


organisation, asking the key questions as to what the customer really needs and how they adapt to deliver good customer outcomes. For many consumer credit firms this


means the development of a new range of products. There is radical thinking going on across the country. For us, as a trade association, we play


our part in ensuring that decisions are made with the best information possible. We are a channel of communication with the regulator, but, just as importantly, we help in the sharing of information amongst the membership.


needs and allows space for growth. Unfortunately, we have seen what happens to financial services when it is left to a small number of big banks: it is often the customers that suffer as their needs are ignored.


Navigating the waters An important role for our trade association has been to help people navigate the tricky waters of Financial Conduct Authority (FCA) authorisation. For those that received interim permission


from the FCA and are now seeking full authorisation, everything has been up for discussion as the firms return to a set of basic questions: lWhat need have they identified? l Have they a strategy to meet that need? l How can they create an effective operating model? lWhat systems and controls need to be in place to ensure good customer outcomes? Over several months these questions


have been part of a process of re-evaluation taking place in many lending firms. And because of its commercial nature


this has often been a private affair. So it was fascinating to read the article by Stuart Howard of Dollar UK in August’s edition of CCR (‘Changing Company Processes For The Better’, pp31-32). He provided an insight as to the restructuring of his


www.CCRmagazine.co.uk


Calmer waters ahead? We have been through so much already. For every lender there has been the development of the Consumer Credit Sourcebook and the introduction of the FCA approach. Those that provide short-term credit


have also been involved in the modelling of the industry which the FCA used to determine a price cap and an 18-month review by the Competition and Markets Authority. Both were huge initiatives, with those firms involved providing information for every transaction and every customer for the previous year. So it has been a busy period. There is


certainly more to come. More reviews will be undertaken, which could include both thematic and company-focussed reviews. The authorisation process remains hard to predict. The BCCA has played a role in helping


to get its members to this point. We will continue to be a source of advice and help. We want to ensure we influence the way in which this market is regulated. What we know is that we cannot do this


alone. By our nature, our strength comes from the members that we represent. We are always open to discussions with others that share our interests. Just as importantly, we want to talk to


those who do not share our view. It is only by reaching out and engaging that we can play our part and add value as a trade association under the FCA regime. CCR


October 2015


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