Consultation response: HMT & DWP Public Financial Guidance Review

Transcription

1 Consultation response: HMT & DWP Public Financial Guidance Review Response by the Money Advice Trust Date: February 2017

2 Contents Page 2 Page 3 Page 4 Page 7 Contents About the Money Advice Trust Introduction and Executive Summary Responses to individual questions HMT & DWP Public Financial Guidance Review 2

3 Introduction About the Money Advice Trust The Money Advice Trust is a charity founded in 1991 to help people across the UK tackle their debts and manage their money with confidence. The Trust s main activities are giving advice, supporting advisers and improving the UK s money and debt environment. Over 1.35 million people were supported by the Trust in 2015, both directly through our advice services or indirectly through training advisers in charities across the UK. This includes almost 400,000 individuals assisted through National Debtline, over 50,000 small businesses through Business Debtline and over 900,000 through our adviser training. We support advisers by providing training through Wiseradviser, innovation and infrastructure grants. We use the intelligence and insight gained from these activities to improve the UK s money and debt environment by contributing to policy developments and public debate around these issues. Public disclosure Please note that we consent to public disclosure of this response. HMT & DWP Public Financial Guidance Review 3

4 About our response Our expertise in this area comes from providing debt advice for more than 25 years and working in partnership with government, creditors, regulators and the wider advice sector including through our Partnership Board, chaired by Sir Brian Pomeroy. At the heart of our approach is our belief in empowering people in debt to help themselves. Our model of assisted self-help advice allows people to control their own debt situation, resulting in better long-term financial health. Our submission is based on our experience as: a charity that aims to see people across the UK tackle their debts and manage their money with confidence; a charity delivering free, independent debt advice for almost 30 years by telephone and online directly to the public, and training debt advisers in other charities; a delivery agency part-funded by the debt advice levy and donations from creditors; a collaborative partner that works closely with other advice sector agencies to achieve the best client outcomes; and an agency delivering financial capability as part of debt advice. Executive summary This response builds on our responses to the earlier consultations on public financial guidance, submitted to HM Treasury in June 2016 and December Many of our comments from previous responses continue to hold. These are included with this submission for ease of reference. Our key points are as follows: Model and remit We are supportive of the proposed single financial guidance body (SFGB) model. A single body will help to ensure greater consistency in the provision of financial and debt advice for consumers across their lifetimes, and in particular, go some way towards addressing concerns we had about the complex link between debt and pensions advice, and appropriate signposting. We support the new body s proposed remit and, in particular its explicit focus on the provision of debt advice for those in problem debt. We also welcome the inclusion of a strategic co-ordinating role on financial capability, as well as the proposed coordinating role in the area of financial education for young people. However, we believe that the latter should not be restricted to non-government programmes only, to HMT & DWP Public Financial Guidance Review 4

5 ensure the maximum possible co-ordination of efforts to improve financial capability in the UK. In addition to the SFGB s overall role, it may be helpful to define separately in legislation its role and responsibilities in relation to money guidance, pensions and debt, as the expectations in each area differ. A starting point for this could be the draft wording and feedback from earlier consultations, which set these out in more detail. The new body should also be obliged to develop its plans in consultation with stakeholders. Role of the SFGB body with regard to delivery of debt advice We continue to support plans for the SFGB to commission services to meet the need for debt advice. The key responsibilities of the new body in commissioning quality debt advice and supporting infrastructure/good practice support should be: o Identifying need o Co-designing multi-channel services with input from stakeholders o Stewarding the market o Identifying appropriate outcomes and output measures o Selecting and identifying providers o Focussing research to support commissioning We believe that the SFGB should only commission not-for-profit advice providers to deliver free-to-client debt advice. This is based on our concern that commissioning for-profit commercial providers would convey to that sector the unwarranted legitimacy of being endorsed by a government-backed body and associated overhead subsidies. There is a risk that this would lend support to the activities of its other, fee-charging debt advice activities, where the added costs, by merit of the fees involved can add to the clients total debt burden. There is a role for the new body to play in taking a strategic approach to supporting the advice sector s infrastructure so that the best outcomes for clients are achieved, and services remain of a high quality. Funding with regard to debt advice As emphasised in previous responses, it likely that funding of debt advice will need to increase. The scale of consumer need for free debt advice is significant, likely to increase and currently unmet by supply. In particular, the public sector (encompassing local government), who are one of the increasing contributors to the demand for debt advice (eg council tax and benefit overpayments relate to a growing proportion of the debts we deal with), should contribute appropriately as a creditor to debt advice funding arrangements. We would also encourage government or the new body to conduct a wider review of the sector s funding while embarking on HMT & DWP Public Financial Guidance Review 5

6 the new approach to commissioning to help put advice funding on a more sustainable footing, and understand better how the different funding streams for debt advice (often coming from the same organisations) can be better aligned. We don t agree that the SFGB should have more flexibility in how it uses the existing ring-fenced levies. In particular, debt advice funding is a form of emergency relief funding for those who are facing severe financial hardship. Accountability arrangements We agree that the body should be overseen by one lead government department. HM Treasury is well placed to take on this role as the government department with responsibility for the FCA, consumer protection in financial services, financial services policy and economic policy. Equally, DWP is a service delivery department where appropriate connections could be made with the welfare to work programme, where debt advice could be joined up with Universal Support, and the pensions agenda. The board should draw in representatives from advice agencies and creditors, ensuring they are acting in the public interest rather than the interest of their own agencies. Devolved administrations We support the plans to engage devolved administrations further in the process for commissioning and awarding contracts for debt advice. HMT & DWP Public Financial Guidance Review 6

7 Responses to individual questions Question 1: Do people with protected characteristics under the Equalities Act 2010, or any consumers in vulnerable circumstances, have particular needs for public financial guidance or difficulty finding and obtaining that guidance? We are pleased to hear that there will be consideration given as to whether there are any particular difficulties that affect vulnerable people or those with protected characteristics in their need for or ability to access public financial guidance. The FCA occasional paper into consumer vulnerability 1 defines vulnerability as follows: A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. We would suggest that many people in debt could be considered vulnerable. Low income and/or debt is listed as one of the risk factors for vulnerability in the paper along with other factors such as low literacy, numeracy and financial capability skills which frequently coexist with indebtedness. It seems to us to be self-evident that many people in vulnerable circumstances will have particular needs for debt advice. In a recent pilot of our National Debtline clients, 21% of our clients were identified as potentially vulnerable in various ways. For example, in surveys of our clients more than 21% state they have fallen into debt due to ill-health or disability and 14% due to mental health issues. Many are likely to be unable to pay for such advice due to being in debt or on a low income, and hence have a particular need for public financial guidance, and have particular difficulty in finding that advice. Arguably, people in insecure work are also more susceptible to being vulnerable, as their resilience and capacity to deal with income shocks is reduced. We find that 24% of our clients fell into debt because they lost their jobs, and a further 11% owing to a reduction in working hours leading to a drop in income. It also seems clear that these vulnerable groups overlap with the some of the groups identified as having protected characteristics under the Equality Act 2010 in particular in relation to age, and disability. Age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Evidence from the Money Advice Service s Indebted Lives report shows that 75% of the over indebted population are aged 54 or under, 50% have a household income of less than 20,000 and 41% are in full-time employment. 2 In all, MAS currently estimate that 8.2m Money Advice Service, Indebted Lives, November 2013 HMT & DWP Public Financial Guidance Review 7

8 people are over-indebted. While the majority of the over-indebted population report that their debt is having a negative impact on their lives, only 17% are currently receiving advice to get help with their debts. 3 The FCA Occasional Paper on Vulnerability details some of the ways in which people in circumstances need support. Evidence of these difficulties has been presented to the British Bankers Association (BBA) Vulnerability Taskforce, chaired by our Chief Executive Joanna Elson. As a result, the Taskforce published a report in February outlining best practice recommendations for the industry with its aim to improve the experience and outcomes of customers who may be facing challenging personal circumstances. The financial services industry is now working on ways to address a number of specific recommendations from the report. Question 2: Do you agree that these areas capture what the broad role of the SFGB should cover? We are supportive of the proposed single financial guidance body (SFGB) model, and broad role outlined. A single body will help to ensure greater consistency in the provision of financial and debt advice for consumers across their lifetimes, and in particular, go some way towards addressing concerns we had about the complex link between debt and pensions advice, and appropriate signposting. We also support the new body s outlined remit and its explicit focus on the provision of debt advice for those in problem debt. If financial fraud and scams are added to the new body s remit, both of which are currently covered by other organisations, then specific funding will need to be identified to cover this area. In addition to the SFGB s overall role, however it may be helpful to define separately in legislation its role and responsibilities in relation to money guidance, pensions and debt, as the expectations in each area differ. We would recommend for this that HMT use the feedback from earlier consultations as a starting point for each, as proposed legislation for each area of focus was covered more explicitly in these consutlations. The new body should also be obliged to develop its plans in consultation with stakeholders. We continue to support plans for the SFGB to commission services to meet the need for debt advice. The key responsibilities of the new body in commissioning quality debt advice and supporting infrastructure/good practice support should be: o Identifying need o Co-designing multi-channel services with input from stakeholders o Stewarding the market o Identifying appropriate outcomes and output measures o Selecting and identifying providers o Focussing research to support commissioning 3 Money Advice Service, Indebted Lives update, December HMT & DWP Public Financial Guidance Review 8

9 The new body should underpin its commissioning activity with research on the need for debt advice, including understanding those in crisis debt versus those at risk of falling into debt, regional disparities, the profile of those in debt or at risk of debt, the current market place for advice, evidence of what works, the capacity of existing supply to meet that need and evaluations of funded interventions. We also encourage a greater focus on customer outcomes, which could be built on the work of the existing Money Advice Service (MAS) debt services evaluation framework. We d also recommend that a theory of change for debt advice is worked up drawing on existing evidence. Debt advice services should be commissioned across all channels that clients use including face to face and digital, and there should be an increasing focus on multi-channel engagement (e.g. interactive websites, web-chat, phone and online advice). As ever, the more expensive channels should be preserved for those who need them most. We welcome the proposal to maintain a consumer-facing website, to which useful tools such as the existing debt advice locator tool can be transferred. However, for detailed debt advice and information, the SFGB should signpost clearly to more expert providers, and support the optimisation of specialist websites. We strongly recommend that the SFGB focuses on its role as market steward, and that the approach to commissioning and procurement be one that encourages collaboration and the best use of the advice sector s resources, as opposed to one that pits providers in competition against each other in a way that depletes the limited existing resources available. The new body should consider how it identifies providers for each individual service, considering, in the process, the shape of the market that currently exists and what marketplace would be best for the future. While contracting may become the norm, we also recognise that there may be times when a better result will be obtained by using grant funding. This should be made explicit in the remit of the new body, so that it is not constrained to a narrow approach with regards to procurement approaches. For commissioned activity, evaluation should include outcomes, some limited monitoring of outputs, complaints and advice recommendations. We would encourage the new body to shift away from the current focus on outputs. We believe that the SFGB should only commission not-for-profit advice providers to deliver free-to-client debt advice. This is based on our concern that commissioning for-profit commercial providers would convey to that sector the unwarranted legitimacy of being endorsed by a government-backed body and associated overhead subsidies. There is a risk that this would lend support to the activities of its other, fee-charging debt advice activities, where the added costs, by merit of the fees involved can add to the clients total debt burden. HMT & DWP Public Financial Guidance Review 9

10 There is a role for the new body to play in taking a strategic approach to supporting the advice sector s infrastructure so that the best outcomes for clients are achieved, and services remain of a high quality. In particular, it should facilitate the delivery of sector training, tools and programmes, for example, quality assurance tools such as peer review, the Standard Financial Statement and training and good practice sessions for debt advisers. While work related to quality of advice services should work with the grain of the regulator (FCA) and not result in unnecessary quality regimes or lead to dual regulation, in our view programmes such as the existing peer review and accreditation are helpful for those organisations that operate under limited permissions and should be maintained. Where new tools and programmes are developed, the new body should ensure that duplication is avoided. As emphasised in previous responses, it likely that funding of debt advice will need to increase. The scale of consumer need for free debt advice is significant, likely to increase and currently unmet by supply. In particular, the public sector (encompassing local government), who are one of the increasing contributors to the demand for debt advice (eg council tax and benefit overpayments relate to a growing proportion of the debts we deal with), should contribute appropriately as a creditor to debt advice funding arrangements. Non-levy funding for debt advice services both donation models and Fairshare - rests largely on a beneficiary pays principle, and these models of funding have come under increasing pressure in recent years due to the change in debt type that agencies are dealing with, and the growing frequency of deficit budgets. We would encourage government or the new body to conduct a wider review of the sector s funding while embarking on the new approach to commissioning to help put advice funding on a more sustainable footing, and understand better how the different funding streams for debt advice (often coming from the same organisations) can be better aligned. Question 3: Do you agree that the SFGB s financial capability initiatives should focus on priority groups such as those who are most in need of support to build resilience? Yes, and we note that this approach is consistent with the government s welcome focus on the just about managing. In identifying and defining the priority groups, the SFGB should draw on the work already done as part of the preparation of the UK Financial Capability Strategy. 5 We would also highlight the importance of ensuring that these definitions are regularly reviewed as the economic context changes, to ensure that financial capability initiatives are achieving the maximum possible impact on those who need them most. 5 Money Advice Service (2015), The UK Financial Capability Strategy, io.s3.amazonaws.com/fincap-two%2fd176f87b-48f d26- afc4df5d86f5_uk+financial+capability+strategy.pdf HMT & DWP Public Financial Guidance Review 10

11 Question 4: Do you agree that the SFGB should have a strategic role, working with the financial services and pensions industry and third sector organisations to improve financial capability? Yes. We welcome the inclusion of a strategic co-ordinating role in the area of financial capability, building on the work the Money Advice Service has carried out through the creation of the Financial Capability Board and preparation of the UK Financial Capability Strategy. 6 This is an area where we believe the SFGB could add significant value, and we welcome the proposed focus on minimising duplication and the continuation of the test-andlearn approach embodied in the Financial Capability Board s What Works programme. We would also point out that the inclusion of a strategic co-ordinating role in the area of financial capability presents useful opportunities for the SFGB to link this work to its debt advice commissioning responsibilities. In addition to its primary aim, debt advice provision should also be seen as an opportunity to improve financial capability in the longer term (this approach is central to the assisted self-help model employed at National Debtline and Business Debtline where clients consistency report better confidence in managing their money and better budgeting skills), and the co-ordination of debt advice and financial capability programmes should be as joined up as possible. We further welcome the inclusion of a co-ordinating role in the area of financial education for young people, but would welcome greater clarity on the scope of this role (see our answer to Question 6). Question 5: How might the SFGB develop its understanding of what works and usefully contribute to sector wide research? In recent years, the Money Advice Service has built up a considerable body of research, focussed on areas of interest to the debt advice sector. There are also a number of helpful projects underway. For example on the effectiveness of debt solutions, the economic value of debt advice, the role of peer support, understanding repeat clients, the impact of changes in economic variables on demand for debt advice, what works for self-negotiators and a planned review of the debt advice sector s infrastructure and training needs. These should all help to inform future commissioning, and the new body should seek to build on this work. It should focus its new research to support its commissioning activity, covering the following areas. The need and demand for debt advice, including understanding this at a more granular level. Understanding the current supply of advice. The capacity of existing supply to meet need. The evaluation of funded interventions. The efficacy of current debt solutions. The research data should continue to be available in open standard format so that it can be used and interpreted by other agencies. We d also support work to better align data within 6 Money Advice Service (2015), The UK Financial Capability Strategy, io.s3.amazonaws.com/fincap-two%2fd176f87b-48f d26- afc4df5d86f5_uk+financial+capability+strategy.pdf HMT & DWP Public Financial Guidance Review 11

12 the sector - possibly through commissioned activity - to give a better picture of what is happening nationally. Germany is a good example of where this happens already whereby all the local agencies share their data with a national agency at year end, giving a comprehensive picture of who is getting help with debt issues. The new body should also seek to work in a co-ordinated way with bodies in the sector, so as not to duplicate existing research. We would suggest that the Sector Research Group recently set up by MAS should continue in some guise, and meet more frequently, possibly to help develop the new body s research programme. Question 6: In what ways could the SFGB co-ordinate and add value to the provision of financial education? We welcome the proposed inclusion in the SFGB s remit of co-ordination of nongovernment financial education programmes for children and young people, but would welcome greater clarity on the scope of this proposed role. In particular, we would question whether the implied exclusion of government provision (through the school system) represents a missed opportunity to achieve the maximum possible impact in the SFGB s broader efforts to improve financial capability. While financial education in schools is more established in Scotland, Wales and Northern Ireland, provision is still bedding in throughout England following the 2014 National Curriculum changes and we believe giving the SFGB a co-ordinating role covering all financial education provision (i.e. that provided by financial services industry, third sector organisations and the education system) would provide the greatest opportunities for the SFGB to help improve the financial capability of the population over time. For example, the SFGB could play a useful role in addressing many of the outstanding challenges identified by the APPG on Financial Education for Young People s review of the 2014 National Curriculum changes in England, including insufficient consistency in provision, and a lack of teacher confidence and skills. 7 The SFGB could also usefully promote greater adoption of financial education in other school settings such as Academies and Free Schools, and at primary school level, as part of this wider co-ordinating role. Beyond this query over the scope of its financial education remit, we would suggest that the SFGB could add value in this area by focusing on reducing duplication of financial education programmes provided by industry and the third sector, and on achieving greater consistency throughout the country. The SFGB could also conduct mapping to identify and fill any gaps in existing provision by industry and the third sector such as programmes targeting hard-toreach groups or the particular needs of groups such as Looked After Children. We welcome the proposed focus on the evaluation of financial education programmes, and on a role for the SFGB in providing leadership and spreading best practice based on learning from which projects have been most successful. Question 7: Are there other delivery channels that the SFGB should consider that would be effective for delivering to consumers? 7 APPG on Financial Education for Young People (2016), %20-Final%20Report%20-%20May% pdf HMT & DWP Public Financial Guidance Review 12

13 We are pleased to see the expectation from government that the SFGB is to provide a multichannel information and guidance service, including a customer facing website, a telephone service to access pensions guidance, and the provision of some face to face support. As the paper says, it is vital to ensure that face-to-face guidance remains available: including for those who are unable to access other forms of guidance due to poor internet and/or phone coverage in their area. It is also vital that debt advice is provided through a range of channels including face-to-face debt advice services which should be available for those who require face-to-face advice due to their particular needs. The sector is becoming increasingly cost effective, to which use of phone and online service is key. Some rationalisation of funding can be achieved through increasing focus on technological innovation and partnership working. This should be further encouraged; however, channel shift must not become an end in itself. Funding of services should be determined by what works best to make the clients situation manageable, while continuing to extend the availability and reach of free-to-client debt advice services. We can only comment on our experience at Money Advice Trust in harnessing new technology to develop new products and to provide advice in new ways. We have outlined how we deliver advice online below. Self-help information online The Money Advice Trust provides debt advice using an assisted self-help model, essentially helping people in debt to help themselves. In addition to our phone services, our National Debtline and Business Debtline websites provide clients with the detailed, holistic information they need to understand their debt situation, determine what they need to do and then support them to take action. For example, our National Debtline site contains 32 debt topics pages, 52 fact sheet pages, 38 different sample letters and a budget sheet people can complete. This enables people who are able to self-direct to access the information they need for themselves, and go on to take action. Our National Debtline website delivered 646,298 advice sessions in 2016 and our Business Debtline site delivered just under 60,000. We know from our websites, that some of the most popular information is our Time limits fact sheet, our budget and the sample letter suite. Web-chat We have also developed a web-chat service. Accessible from our webchat service gives our clients the option of receiving free, independent debt advice online. The technology behind our webchat service allows the users to initiate a chat session using the pop-up that appears when the visit our site or using the side bar visible on every page. Once a chat session is initiated it is queued to a waiting adviser who is alerted by our telephony system. During a chat session the client can be signposted to fact sheets sample letters and any other online information. Our webchat services have proven to be hugely popular with consumers. Since its launch in May 2014, National Debtline s webchat service has delivered over 70,000 advice sessions HMT & DWP Public Financial Guidance Review 13

14 (up to the end of December 2016). The service has grown month on month and now regularly handles above 3000 advice sessions each month. The Business Debtline webchat service has also proved to be popular and has delivered over 5,000 advice sessions since launch. Online advice tools There are also more tailored online tools offered by the main free advice providers. For example, My Money Steps is our comprehensive online budgeting and debt advice tool. It works on our library of rules, logic and suggestions. Once a user has answered a series of questions about themselves they are given debt advice that is tailored to their personal circumstances. My Money Steps builds a personalised action plan with prompts and deadlines and step-by-step guides. It also prompts the user to take action and update their profile to maintain progress with their situation. Taking a multi-channel approach Our plans to integrate our CRM with our redesigned interactive online tool will further improve the accessibility of our services and user experience of our clients offering them a seamless multi-channel journey to free, tailored and high quality advice. Our research suggests that the profiles of clients using our telephone and online channel offerings may vary slightly. For example, users of our online tool My Money Steps are likely to be younger than our phone clients and also more likely to be in employment, perhaps reflecting the convenience of being able to access advice at a time that fits in with busy working lifestyles. However, we are aware that many clients will access multiple channels whilst seeking a resolution to their debts so it cannot be assumed that the channels, and the client groups using them, exist in isolation from each other. Nonetheless, by identifying that there may be variations in the way different client groups want to engage with debt advice we hope to be able to reach as wide an audience as possible with a view to contributing to the breaking down of barriers that can prevent people getting the help that they need. We would recommend that the new money guidance body explores these types of online services when identifying what support might be available for people in debt. Working to support face-to-face services (debt and non-debt) Our self-help guides (developed for the UK and Scotland), CASHflow tool, and fact sheets are also provided to face-to-face clients through a range of local free debt advice and other service providers. In 2016, local advice agencies provided the self-help guides to over 28,000 face-to-face clients across the UK. Our provision of these guides is responsive to demand from local agencies, and we know from a recent survey of agencies that, despite the rise of online resources, this continues to be a valuable source of information and guidance for many. This is also particularly true of local agencies that are not debt advice specialists, but who come into contact with many of their own beneficiaries who are in debt and want to be able to support them. Question 8: How should the SFGB ensure that it engages consumers at the right time for them? HMT & DWP Public Financial Guidance Review 14

15 In our experience, debt advice has better results when used at an early stage. We are therefore advocates of early intervention as advice at an early stage will normally result in more options being available. However, it is a great challenge to ensure that people seek that advice at an earlier point in their debt problem, before it spirals out of control. We are working with the sector, credit industry and the Money Advice Service to try to identify the key points where people are more likely to seek advice. These may be life events such as having a baby, going to college, marrying or divorcing, retiring and bereavement, or changes in circumstances such as job loss, sickness and redundancy. If advice is offered at key points, is it more likely to be acted upon or taken up because it is of immediate relevance. The need for debt advice does not tend to exist in isolation. Most people will have overlapping problems that are not directly to do with their debts. These may relate to welfare benefits and income, physical and mental health, housing, legal problems to do with employment, relationships and so on, as well as pensions and savings. People may expect to receive holistic advice from one source, although this would be extremely difficult to achieve given the complexity of the various areas of advice that would need to be incorporated and the skill levels would be unachievable for advisers to allow them to be experts in all areas. Much of the evidence points to consumers wanting and benefiting from proactive advice at key life events such as starting a job, buying a house or having a baby. By tapping into consumers at these key touch points, and working in collaboration with trusted organisations, there is potential to have an effective impact throughout their lives on issues that are relevant to them. This approach is reflected in MAS s recently published Financial Capability Strategy. Similarly, it can be more effective to reach people in the physical and virtual spaces they engage (such as schools, workplaces, banks or through online forums), rather than trying to reach them through stand-alone venues or websites. For example, our advisers provide advice through MoneySavingExpert and other forums and can achieve a reach well beyond our normal service. There is also learning that could be drawn from some of the referrals models we use. For example, many utilities companies will promote our services to their clients when sending out bills. Whilst there are instances where we can agree these partnerships ourselves, early intervention partnerships, in the debt and general money advice space could be beneficial. Question 9: Do you agree that the SFGB should be able to exercise some flexibility in the way funding is directed? We don t agree that the SFGB should have more flexibility in how it uses the existing ringfenced levies. In particular, debt advice funding is a form of emergency relief funding for those who are facing severe financial hardship. Our concern is that, with resources already limited and considerable unmet demand, this could become even more diluted. Furthermore, levy contributors increasingly seek assurance on the use and effectiveness of funds. For example, funds now intended by levy payers specifically for debt advice could end HMT & DWP Public Financial Guidance Review 15

16 up, over time, being allocated to financial capability projects, or pensions issues. There are obvious overlaps in these areas, but ensuring that interventions are joined-up can be addressed in the design and commissioning of services. Question 10: Would these proposals have any impact on the delivery of public financial guidance in Scotland, Wales or Northern Ireland? We consider it important that the new guidance body engages closely with the advice sector and public bodies in Scotland, Wales, and Northern Ireland to understand the specific circumstances of each jurisdiction. Our experience of the commissioning process in Northern Ireland has highlighted how important it is to understand the unique debt delivery landscape in each jurisdiction, working closely with the local advice sectors and public bodies, as opposed to adopting a blanket approach. Furthermore, the law is more likely to continue to diverge as devolution develops. For example, in Wales, the Welsh Government plans to introduce new mandatory targets at local level that may relate to indebtedness under their Wellbeing of Future Generations Strategy. Equally in Scotland, a new debt solution, the Debt Arrangement Scheme, was introduced some years ago to help people who are able to make regular reduced payments to their creditors. This is supported by the Scottish Government, and forms a pillar of the debt advice landscape in Scotland. The impact will therefore depend on the changes made in these administrations. The money guidance body will need to consider how policies and arrangements such as these, impact on longer-term levels of indebtedness and provision of advice when commissioning support. For this reason we also support the presence of a MAS representative in Wales, Scotland and Northern Ireland, which we have found hugely useful in our work in each jurisdiction. We think this approach will need to continue under the new bodies. Question 11: Do you have any other comments about the proposed delivery model and consumer offer? No HMT & DWP Public Financial Guidance Review 16

17 For more information on our response, please contact: Meg van Rooyen, Policy Manager HMT & DWP Public Financial Guidance Review 17

18 The Money Advice Trust 21 Garlick Hill London EC4V 2AU Tel: Fax: HMT & DWP Public Financial Guidance Review 18