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CCR2 Affordability Assessments & Vulnerability


“We would like to take the opportunity to


commend you for the high level of quality and effort that has clearly been put in to designing,


implementing, and quality marking this course that so importantly raises awareness of vulnerability and mental health.”


Taking Control of Goods Regulations 2013 and further provision is provided on the recovery of fees from vulnerable debtors in Regulation 12 of the Taking Control of Goods (Fees) Regulations 2014. Under this regulation, the enforcement agent is required to give a vulnerable person an adequate opportunity to obtain assistance and advice before proceeding to


March 2017


remove goods which have been taken into control. The fee (or fees) for the enforcement stage, and any disbursements related to that stage (or stages), are not recoverable if no such opportunity has been given. This is why appropriate training is so essential for enforcement agents when enforcing writs and warrants of control, so that they are sensitive to potential vulnerabilities and are fully aware of the degree of protection that exists. They must understand that, while people who fall into vulnerable categories may have particular shared characteristics, not everyone in one of those categories will necessarily be vulnerable, and also that there may be vulnerable people who fall outside those categories.


Key characteristics


There are many characteristics that may make a debtor vulnerable, and impact in different ways, their capacity to protect, or represent, their interests. These include, but are not limited to:  Living with physical health issues or a mental illness.  Suffering from a cognitive impairment.


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 Having a learning disability, literacy or numeracy difficulties.  Having speech impairment.  Not speaking English as a first language. David Grimes, our head of training and development, who developed these new Level 3 courses, says: “Awareness of vulnerability and mental health should be a fundamental component in the enforcement agent’s toolbox, not only enforcement agents, but also administration staff involved in civil enforcement.


“All our enforcement agents and welfare teams have received awareness training in vulnerability and mental health. “Training of enforcement agents must be ongoing. Awareness of vulnerability and mental health should be a requisite for enforcement agents in the twenty-first century.”


We promote ethical enforcement in the prompt collection of all sums of money due, while ensuring that a fair, proportionate, and consistent approach is taken to enforcement recovery.


This is why we are making access to these qualifications open to all across the enforcement industry. CCR2


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