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Opinion


Regulator contacts card firms on persistent debt


Do you have a question about VAT?


CCRMagazine is asking for questions that will be put to the man who highlighted the inconsistencies in High Court enforcement and the application of VAT. We will be interviewing Jamie Waller,


Last month, the Financial Conduct


Authority (FCA) wrote to credit-card firms telling them to review their approach to borrowers who are stuck in persistent debt. This is another clear demonstration of the


FCA’s ongoing commitment to prioritising better outcomes for vulnerable customers, particularly those who find themselves in perpetual financial difficulty. Identifying and taking appropriate action


for those at risk or in financial distress is key for firms to support vulnerable consumers. It is crucial that firms invest in appropriate


systems and high-quality training for frontline staff to spot and support consumers in persistent debt. Firms should also undertake an assessment


of their internal policies and procedures to ensure that they are designed to identify and support vulnerable customers in line with evolving best practice. Investing in these measures will not only


satisfy the regulatory requirements, but also help minimise the potential for persistent debt to accumulate in future.


Paul Dyer Head of regulatory risk and assurance, Huntswood and former deputy chief risk officer, the FCA


founder and chairman of Just, so if you have a question that you would like us to ask, please e-mail the address below before 6 March 2020. The interview will be held immediately


after the Ministry of Justice (MoJ) issue formal guidance for publication which is forecast to be within the next few weeks. Mr Waller has led the discussion on VAT


since August 2019 and has been in dialogue with HMRC,


the MoJ, government


ministers, MPs, and multiple government officials in a bid to give clarity to the creditors that employ the services of High Court enforcement providers and protect their reputations. Any changes in VAT guidance will be in


direct response to this engagement from Mr Waller and his team. Mr Waller commenting on the forthcoming


guidance said: “Just has been working with government to clarify the VAT issue since the summer of 2019. “We sought clarification as we were


concerned that some High Court enforcement businesses were charging creditors, while others were charging debtors and we were about to launch a solution and we needed to know who we should charge. “HMRC and the MoJ quickly confirmed,


standard VAT rules apply and that the customer who is the beneficiary of the service is liable to pay VAT and where VAT registered, they can reclaim this as a typical cost of business. “On publication of this confirmation we expected the matter to be resolved. Many


Jamie Waller


businesses, however chose to ignore this, and instead wait for guidance from the MoJ. We do not understand why this issue has been left unresolved since the implementation of the new regulations in 2014. “It makes no sense why we are having this


discussion six years on when the matter seems so clear. “The MoJ policy guidance is now imminent,


and we are delighted to have brought this matter to a conclusion.” CCRMagazine will be eagerly awaiting


the guidance to be published and, once it has been reviewed, we will then interview Mr Waller to put your questions to him. This interview will be featured in an upcoming edition of the magazine. l To put a question to Jamie Waller, please e-mail it to stephen@ccrmagazine.co.uk.


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www.CCRMagazine.com


February 2020


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