Money Advice Trust response to the Financial Conduct Authority consultation on High-level proposals for an FCA regime for consumer credit

Transcription

1 Money Advice Trust response to the Financial Conduct Authority consultation on High-level proposals for an FCA regime for consumer credit 1 About the Money Advice Trust The Money Advice Trust (MAT) is a charity formed in 1991 to increase the quality and availability of money advice in the UK. We work with the UK s leading money advice agencies, government and the private sector to increase the availability of money advice, improve its quality, and enhance the efficiency and effectiveness of its delivery. MAT s vision is to help people across the UK to tackle their debts and manage their money wisely. MAT aims to support individuals and micro-businesses in the UK through their debts and into financial health, and to improve the capability, quality and efficient delivery of free independent money advice by: Delivering advice to the public via National Debtline, Business Debtline and My Money Steps; Supporting advisers; Making the case for free money advice; Coordinating initiatives to improve money advice; Sharing research and information to shape and influence policy. Please note that we consent to public disclosure of this response.

2 2 Introductory Money Advice Trust comment We are extremely pleased to see the advent of the Financial Conduct Authority and its enhanced powers of consumer protection and product intervention in particular. Overall, we welcome the proposals in the consultation paper. We particularly welcome the decision to carry forward most of the CCA provisions, and most specifically those that provide enhanced consumer protections. We also welcome the intention to retain OFT guidance and translate the guidance into FCA rules. We have some concerns about the proposed definitions of debt advice and the corresponding levels of regulation to each category as we feel these could be open to abuse by less scrupulous firms. We also feel it is important to ensure that regulation of free-to-client advice providers is proportionate and does not lead there to be any possibility of fee-charging debt management providers arguing that they are providing a better regulated service. We believe it should be clear that higher regulation of debt management companies is required because they have been repeatedly shown to be high risk and to cause consumer detriment through bad practice. Perhaps a new title for the limited permissions regime might assist with resolving this issue as this title can give the impression that firms in that category have had their permissions restricted in some way. Perhaps higherrisk and lower-risk permissions might be appropriate. Alternatively, a third tier for free-to-client advice providers could be considered to make the position more clear. We have outlined any concerns in our response below. 3 Comments on individual issues Q1: Do you agree that our proposals strike the right balance between proportionality and strengthening consumer protection? The proposals outlined in the paper appear to us to strike the right balance between the aim of strengthening consumer protection but acting with proportionality. Q2: Do you agree that we have included the right activities in the higher and lower risk regimes? We welcome the proposals for the new authorisation regime which we hope will deliver a more effective regulatory regime for consumer credit. In general, we agree that the correct activities have been placed in the higher and lower risk regimes. Our experience of dealing with the difficulties National Debtline and Business Debtline clients have had when using fee-charging debt management

3 companies leads us to particularly welcome the allocation of fee-charging debt advice to the higher risk activity group. We welcome the approach taken for not-for-profit debt advice agencies. From the perspective of a free-to-client debt advice provider, we would agree that the limited permission authorisation should apply to not-for-profit debt counselling providers. There appears to be little evidence of consumer detriment across the sector and it would appear to be a proportionate response that mirrors the approach taken by the OFT to lower risk categories of licence holder. We would query the category that allows debt counselling to be lower risk when carried on as an ancillary activity by a person already in the lower risk category. We cannot envisage when it would be appropriate for anyone in the list such as a secondary broker or consumer hire company to provide debt advice. We agree that if a firm carries out other credit activities not covered in the list as well, that it should be subject to the core authorisation regime instead. Q3: Do you agree that our proposals minimise the impact on competition within the regulated consumer credit market? As a free-to-client debt advice provider, we are not best placed to comment on the impact on competition within the regulated consumer credit market. Having said that, we feel that the proposals in the paper appear to be both well thought out and proportionate. Costs to firms appear to have been minimised by creating the interim permissions regime and keeping much of the existing Consumer Credit Act provisions in place. Q4: Do you have any comments regarding our proposals for the interim permission regime? The interim permission regime, as set out in the paper, seems to be a workable solution. The limited permission regime for firms that are deemed to be lower risk seems to be a sensible approach. However, the FCA must not allow firms subject to the interim permissions regime to enjoy any lapse in scrutiny and policing. The FCA must ensure that firms are not able to let bad practice develop in the hiatus before the implementation of the full regime. We would urge the FCA to take a rigorous approach to any decision to supervise consumer credit firms through event driven and issues-based supervision as set out in paragraph Clearly there are products and market areas such as payday lending, bills of sale and fee-charging debt management companies that have been unambiguously identified as problematic through the work already carried out by the OFT. Such areas require a systematic and structured strategy using the evidence that has already been collected to formulate a robust plan of action to tackle consumer detriment in these areas. It is important however that the FCA does not overlook the consumer detriment that can be caused by the more mainstream high-street lenders.

4 We urge that plans are made for a series of early thematic reviews of the consumer credit sector during the interim permission regime. Q5: Do you agree that we should apply the Threshold Conditions as proposed? We welcome the tougher threshold conditions and the additional powers to remove or vary permissions with immediate effect. Q6: Do you agree that it would be appropriate for the FCA to apply the approved persons regime activities as proposed? We are not familiar with how effective the approved persons regime is for existing FSMA activities. It would appear to make sense to adopt a similar set of requirements for consumer credit firms as part of the full regime. Q7: Do you agree with our proposal not to apply a customer function to any consumer credit activity, particularly debt advice? We have particular concerns over the proposal not to apply the customer function to fee-charging debt management companies in particular. This means that the individual staff in debt management company call centres are not therefore required to be approved persons to carry on the activity of giving advice to their customers. We suggest that this decision should be looked at again as we are concerned that advice provided by staff in debt management companies is not always holistic, balanced and in the best interest of consumers. It has long been the case that concerns have been raised by consumers, advisers and the OFT about the level of objectivity and balance provided when putting forward options in a profit-driven environment where it can be tempting to push a particular debt solution. The OFT debt management compliance review 1 found: Frontline advisers working for debt management companies generally lack sufficient competence and are providing consumers with poor advice based on inadequate information. If it is decided to not apply the customer function to fee-charging debt management companies, we would expect the function of compliance oversight to ensure the compliance and competence of the firm s advisers to be set out in a set of detailed requirements, adherence to which would need to be closely monitored. We would support the proposal to keep this policy under frequent review. We agree with the proposal not to require not-for-profit debt advice providers to have any approved persons as this would be an extremely onerous requirement for small charities in particular with limited resources. We welcome this recognition that our sector is considered to be low-risk and 1

5 responsible. We agree that each not-for-profit debt advice provider should have a named individual responsible for dealing with FCA concerns. Q8: Do you agree with our proposed approach to appointed representatives and multi-principal arrangements? The working of the appointed representatives regime is not an area that we are particularly familiar with. We would urge the FCA to closely monitor the impact of the proposed changes to ensure that no unexpected consumer detriment is created by the implementation of the plans. We support the proposal to limit appointed representative debt collection businesses to entering into one single-principal arrangement with a creditor or lender. It is very important that a consumer is not misled as to who the debt collection agency is acting for. We have had many instances over the years of it being unclear if the agency is a separate body or is another name for a collection arm of the creditor. It is also common for multiple collection agencies to try to collect the same debt simultaneously. This practice causes confusion and can intimidate. Both the Lending Code and the OFT Debt Collection Guidance has tried to deal with such practices in the past. A more rigorous underpinning of the requirements on firms will be welcome and will hopefully, reduce instances of consumer detriment with all the associated cost benefits of fewer complaints to the Financial Ombudsman Service, which is already overburdened. Q9: Do you agree with our proposed approach to self-employed agents? As long as the FCA continues to hold the credit provider fully responsible for the conduct of its agents when carrying out business as proposed in paragraph 5.16, then we accept the proposed approach. This needs to be subject to close scrutiny to ensure this arrangement continues to function and is not open to abuse by either home-collected credit firms, their own agents or agents that attempt to avoid having to be approved as a small business in their own right. We would support the continued exemption for agents of mail order firms who act as preferred customers for firms. Q10: Do you agree with our approach to professional firms? We have no comment to make on the proposals for professional bodies schemes which appear reasonable. We support the proposals in particular that insolvency practitioners who are carrying on debt-related activities should seek full authorisation. This is because such activity is not incidental to the provision of professional services by that firm. We have come across many instances of consumer detriment in relation to debt management companies that offer individual voluntary arrangement advice as well as debt management plans (so-called IVA factories ). A requirement for full authorisation in such cases would be

6 consistent with the FCA approach to commercial debt management companies. Q11: Do you agree with our proposal to apply prudential standards to debt management firms only? We strongly support the proposal to apply prudential standards to debt management firms. We have seen the effect on vulnerable consumers when companies fail to pay their clients money across to creditors. Such clients are afforded no protection against their creditors in such circumstances as creditors can continue to press them for money that the clients have, in effect, already paid. We agree that there is a high risk of harm for consumers in this position. We have seen too many instances of client money disappearing when a debt management company collapses or is closed down due to alleged fraudulent activity such as in the recent case of Debt Help Direct. We would, however, suggest that the capital requirements should be brought in immediately and not wait for the full permissions regime in Any delay in implementing these measures adds to the risk of further consumer detriment. We agree that it seems disproportionate to require consumer credit firms to adopt the same prudential standards as the disruption for consumers is less direct and any effect less harmful. Q12: Are there any difficulties in collecting data on the size of debt contracts being negotiated and/or the amount of client money held (as the basis for our prudential standards)? We are unable to comment on this question beyond a general point that this sector has been difficult to measure in terms of size and market share in the past, as there is little independent monitoring. This point was acknowledged in the Money Advice Trust research into the debt management industry in It has also been raised in various government consultations that there is no routine reporting of the number of debt management plans, which the Insolvency Service is hoping to partially remedy through a reporting requirement in the Debt Management Protocol. (This will only be a requirement for protocol complaint debt management providers so will not provide a full or reliable picture.) Q13: Are there other measures that would ensure our prudential regime for debt management firms targets the firms that pose the greatest risk to consumers? We would urge the FCA to ensure that the prudential requirements also apply to models of fee-charging companies that offer to help consumers to go 2 An independent review of the fee-charging debt management industry Personal Finance Research Centre & Money Advice Trust

7 bankrupt in return for a high fee. This should also apply to companies that target people already in debt options such as Individual Voluntary arrangements (IVAs) and persuade them that their IVA has been miss-sold. They then are persuaded to go bankrupt instead, again for a large fee. Other practices include firms that target those who have gone bankrupt and offer services to annul the bankruptcy, charging high brokerage fees to try to organise short-term high-risk secured lending or bridging finance, again for high fees. Q14: Do you agree with our proposals that the new high-level conduct requirements should apply from 1 April 2014? Yes we agree that the high-level conduct requirements should apply from 1 April Q15: Do you agree with our proposed approach to financial promotions? We have some concerns with the plans to exempt debt collection and debt administration from the planned financial promotions regime. Whilst we appreciate that promotions advertising such services are generally targeted at lenders rather than consumers, this will not apply in the case of small businesses which may need the services of a debt collection agent to pursue a supplier and other debtors of the business. We are also convinced that credit information and credit reference services should be controlled promotion activities and hope you will be prepared to reconsider on this issue. We have seen many cases over the years of National Debtline clients being persuaded by the dubious advertisements and claims made by credit repair companies, to believe that their county court judgments can be wiped out in a return for a fee, and so on. We would suggest that the Advertising Standards Authority has insufficient powers or relevant experience in this area to provide an effective enforcement regime. We would argue that these areas should be kept within the scope of the FCA promotions regime. We welcome the intention to consult on the proposed financial promotion rules in the Autumn and in particular the commitment to consider new rules where there is evidence of harm in relation to advertising for payday loans, debt management companies, cold-calling and other unsolicited marketing activities. Q16: Are there provisions within industry codes that you think should be formally incorporated into FCA rules and guidance? We have seen over the years that industry codes can work for consumers because they can be more agile in their ability to respond to evidence of consumer detriment and can be amended faster than legislation and statutory guidance. This is particularly the case with the Lending Code operated by the Lending Standards Board which has worked well over the years.

8 On the other hand, where there are instances that industry codes have gone beyond the requirements of the CCA or OFT guidance, we would definitely support considering formally incorporating such codes into FCA rules and guidance. Examples would include the Lending Code and the Consumer Charter for payday lenders. We consider that FCA rules that are binding upon a whole market or industry to be generally an improvement on a voluntary code. In many cases a voluntary code will only bind members of a trade body. In our experience the voluntary nature of such codes makes it very difficult to enforce as this depends upon the willingness of a trade body to take enforcement action against its own members. The consequence of which, can frequently be seen to be the company withdrawing from trade body membership altogether. The enforcement tools held by trade bodies are generally minimal and the consequences of non-compliance for the company equally minimal. We would suggest that the FCA consider codes such as the Debt Management Protocol, the Lending Code, and the payday lending charter. However, caution needs to be exercised. In some cases, such as the payday lending charter, the code does not in itself go far enough and needs substantial improvement. We believe that further work in this area would be imperative, even if the elements of the code were to be made binding upon the whole industry. If any codes remain outside FCA rules there could be a requirement to gain FCA approval, and for the provider to publish detailed data on performance against the code. We would also welcome the introduction of some consistency in the language used by codes so that terms such as we will carry out an affordability check or sustainable mean the same thing in code A as they mean in code B. Q17: Do you agree with the different standards that we propose to apply to different types of debt advice? We have a number of concerns over the FCA intention as outlined in paragraph 8.4: to apply different rules to different types of advice, reflecting the different nature of the advice and associated risk. We are concerned that the scope for grey areas here is enormous. We do not believe that in the real world, advice providers can be reliably separated by the distinctions outlined in the paper. There will always be overlap. We are struggling to identify a provider of advice who would say I recommend not borrowing more than you can afford. (paragraph 8.3) and not say any more than that. We recommend that this whole area is revisited. Should this set of proposals remain, there needs to be very clear definitions setting out what is meant by the descriptors: generic debt advice, advice provided without identifying debt solutions and advice provided; including entering into a

9 particular debt solution. In addition, we would like to see named examples of types of agencies or firms that would fit the descriptors. As far as we can see the proposal is that where no particular debt solution is recommended, the FCA is proposing that it is sufficient for the provider to observe the FCA s high-level Principles for Business. This leads us to wonder what sort of organisations the FCA has in mind who is a Provider of debt advice [that] does not identify or recommend a particular debt solution to a borrower. This sounds like a description of incomplete advice. We are not convinced that a company can provide some debt advice without saying we suggest you do x or y. Whilst this advice may not lead to a suggestion that the client take up a particular debt solution, (even where this would actually be the best advice!) any advice could lead to decisions that might have severe consequences for the client. If the company/creditor is not trained to provide holistic debt advice and licensed accordingly, then they would be much better off restricting their advice to a requirement to signpost to free-to-client services rather than providing partial advice. We are concerned that less scrupulous debt management companies may try to avoid full regulation by attempting to be reclassified to a less regulatory onerous category. We are also concerned that brokers and lead introducers will try to avoid full regulation by saying that they do not offer debt solutions. The categories do not appear to cover these elements of the industry. It is also difficult to envisage what new variants will emerge over time, but it is vital to build in the ability to future-proof the definitions as far as possible. Alternatively there may be DMCs who attempt to come up with convoluted debt options that they can argue do not constitute debt solutions again to avoid regulation. We predict argument around whether individual firms are recommending a particular debt solution for any one individual in debt, giving less specific advice with no solution recommended or even providing generic debt advice. We understand that not-for-profit debt advice providers will be subject to regulation through modified threshold conditions. However, the intention of the FCA is to require both fee-charging and not-for-profit debt advice firms to be subject to comprehensive conduct of business rules (incorporating the OFT Debt Management Guidance) where they are advising consumers to enter into particular debt solutions. This seems to be a reasonable approach which given our comments above, we would suggest may also need to apply to all providers of debt advice Clearly there will be elements of any rules that would not apply to most not-for-profit advice providers e.g. where they do not keep clients monies or distribute payments to creditors. Q18: Do you agree with our proposed approach to applying client asset rules to debt management firms?

10 Yes, we strongly welcome these proposals. We particularly support the intention to provide extra protection for consumers by strengthening the client assets regime for the largest debt management firms. However, we wonder if the potential advantages for clients of strengthening the client assets regime for all debt management firms would outweigh the perceived disproportionate costs falling on smaller firms. Q19: Do you have any comments regarding our proposed approach to peer-to-peer platforms? We strongly support the creation of a new regulated activity for peer to peer platforms. This should hopefully ensure that both consumers who borrow and those that lend are protected. Although we are not aware of instances of consumer detriment in the area of peer to peer lending, this is a relatively new industry and it is important to pre-empt any future problems emerging by ensuring appropriate regulatory protection is in place. Q20: Do you agree with our proposed approach to authorised firms which outsource the tracing of debtors to third party tracing agents? We are not convinced that third-party tracing agents should be exempt from regulation. Even if they are not conducting any financial activities as part of their tracing activities, we have some concern that their actions would not be sufficiently policed and controlled. We understand that the intention is to make the firms hiring tracing agents to be held responsible for their activities, but would urge the FCA to ensure that this system is sufficiently robust. We can see that it will be relatively easy to monitor the quality of the information that firms hiring tracing agents provide, so firms can be held accountable in this way. However, we are not sure how firms will monitor tracing agents that are using illegal methods to gain information. Would there be a temptation for lenders to be less vigilant in monitoring bad behaviour by their agents if they were happy with the results? What controls would be put in place to ensure that the tracing agent did not covertly use illegal or clandestine methods to gain information about individuals? What protections would be in place to protect wrongly identified consumers? Q21: Do you have any comments regarding our proposed approach to supervision and regulatory reporting? As we have said above, we are concerned that an emphasis on event-driven work will not be appropriate for certain high risk areas such as payday lending and fee-charging debt management and log book loans. We are reassured by section 9 of the paper which outlines how the FCA will take action where there is concern across a wide range of firms or in relation to a particular product or service. This will be by way of certain sector-wide projects being undertaken by a specialist sector team. We suggest that sector-wide thematic reviews of those products that attract the most complaints might be a way forward.

11 We would welcome an ongoing commitment to work with consumer groups to identify consumer complaints, and look at intelligence relating to trends and sector developments. We welcome the decision to align the supervision of consumer credit advertising with the supervision of the existing financial promotions regime. We would hope this would lead to action in the area of misleading on-line advertising for debt management companies and lead generation companies where there are some who masquerade as free services and give misleading information about debt solution services. In many cases such activities breach the OFT Debt Management Guidance and the OFT Misleading Names Guidance. 3 We look forward to the consultation on the financial promotions rules that may include new rules following concerns raised about certain highcost credit products such as payday loans, and adverts for debt management companies. As we have said in our response to the Treasury paper, we have some concerns with the plans to exempt debt collection and debt administration from the planned financial promotions regime. Whilst we appreciate that promotions advertising such services are generally targeted at lenders rather than consumers, this will not apply in the case of small businesses which may need the services of a debt collection agent to pursue a supplier and other debtors of the business. We are also convinced that credit information and credit reference services should be controlled promotion activities. We have seen many cases over the years of National Debtline clients being persuaded by the dubious advertisements and claims made by credit repair companies, to believe that their county court judgments can be wiped out in a return for a fee, and so on. We would suggest that the Advertising Standards Authority has insufficient powers or relevant experience in this area to provide an effective enforcement regime. We would argue that these areas should be kept within the scope of the FCA promotions regime. Q22: Do you have any comments regarding our proposed approach to enforcement? We welcome the FCA s proposed approach to enforcement and the advent of greatly increased powers to deal with issues causing consumer detriment in the consumer credit sector from April We particularly welcome the commitment in section 10 to take up OFT open investigations from April 2014 and continue any investigation and enforcement action begun by the OFT. 3

12 Again we would welcome an ongoing commitment to work with consumer groups to identify consumer complaints, and look at intelligence relating to trends and sector developments. We can see the merit in the proposals to repeal some of the criminal offences in the CCA. It is very important that there is no inadvertent resulting drop in consumer protection as a result of criminal offences being repealed. We are not wholly comfortable with the proposals as they stand. We have raised our concerns in our response to the Treasury paper. Q23: Do you have any comments regarding our proposed approach to complaints and redress? We strongly support the intention of the FCA to require consumer credit related firms to report and to publish complaints information. This will hopefully enhance transparency and drive up good practice. We also welcome the intention to allow all micro-enterprises to complain to the Financial Ombudsman Service (FOS). We also welcome the opportunity to join the Financial Ombudsman Scheme under the voluntary jurisdiction as this could provide an assurance for clients of an element of free, independent scrutiny for complaints in the sector with the added assurance of free redress if wrong advice is given. This approach will also be an advantage for our sector as more transparent complaint handling process could help to serve to drive standards in the sector even higher. From the Money Advice Trust perspective, we would be happy to fall under the FOS compulsory jurisdiction. Ideally all free debt advice agencies would fall under the FOS compulsory jurisdiction but we appreciate that this could be challenging for smaller advice agencies with fewer resources. If the FCA goes down this route, they will need to ensure that both the costs and administrative and reporting processes are proportionate for free-to-client agencies. Perhaps a reduced level of fee for complaints (after the first 25) could be put in place. We believe there is a lot of merit in the FCA working with the sector to facilitate a move over to the FOS complaints jurisdiction. We are concerned that there may be unintended consequences if the not-for-profit sector does not move over to FOS en masse, for example, individual lenders and trade bodies that currently refer and signpost to our sector, may be less happy to do so in future. Q24: Do you have any comments on our proposed approach to tackling financial crime? We support the proposed approach to tackling financial crime. Our reading of the proposal leads us to believe that as an organisation that is currently covered by a group licence, we will be exempt from the definition of

13 consumer credit financial institutions that will be subject to the Money Laundering Regulations. However, it is unclear what the position will be, once the group licence regime comes to an end. Perhaps you could provide further clarification in due course. We would be very concerned as to how charities such as very small not-for-profit debt advice organisations would meet any requirements for a Money Laundering Reporting Officer. Q25: Do you have any comments on our proposed interim permission fees? This appears to be a proportionate approach to the transfer of standard consumer credit licence holders from the OFT to the FCA. As a group licence holder, this is not applicable to the Money Advice Trust. However, we welcome the recognition under paragraph that requiring not-for-profit debt advice providers to pay annual fees would affect the ability of some organisations to maintain a free service. We are interested to note the proposed approach (set out at paragraph 13.15) that the largest lenders should meet the costs of regulating the not-for-profit sector. This echoes the approach taken by the Money Advice Trust funding model working party. Q26: Do you agree with our proposed approach for the FOS general levy for firms with an interim permission? We trust that the FCA and FOS will ensure that the interim fees will be charged at a rate that ensures adequate funding for FOS to carry out its role in resolving consumer credit complaints. Q27: Do you agree with our market failure analysis? We have not identified any issues we wish to raise in relation to the market failure analysis. Q28: Do you agree with the costs and benefits identified? We have again, not identified any issues we wish to raise in relation to the costs and benefits identified. Q29: Do you have any comments regarding our proposed approach to second charge lending? We support the transfer of second charge lending into the interim regime along with other forms of consumer credit in April We understand this is subject to further consultation on the long-term regulation of second charge lending, once the proposed Mortgage Credit Directive is in place. We would like to see proposals based on taking the best consumer protection measures from both the Consumer Credit Act (CCA) regime and that of the Financial Services and Markets Act (FSMA). We suggest that a market that is fair, stable and efficient is a market with consistent and meaningful consumer protection. Such protection must cover pre and post-contractual matters

14 including selling, lending, arrears management and individual consumer redress when things go wrong. Whilst we appreciate the aim of the FCA to avoid unnecessary burdens on firms, the proposal to allow second charge lending firms to retain interim permissions, until the new regime is devised for second charge lending, could lead to a long delay in action and raise the risk of further consumer detriment. During this period, second charge lending firms would not be subject to the additional requirements on firms that apply in the full consumer credit regime. We would suggest that this is an area where potential consumer detriment is high, in the experience of callers to National Debtline and Business Debtline. The market may be flat currently due to the effects of the recession, but consumer detriment could escalate if the market for second charge lending was to rise again. We suggest a close eye is needed on the second charge lending market and the proposed strategy reviewed if necessary. Q30: Do you agree with our initial assessment of the impacts of our proposals on the protected groups? Are there any others we should consider? We think it highly likely that more vulnerable groups are more likely to fall into debt or once in debt to feel the effects of enforcement more keenly than other sections of the population. For relevant research see Unmanageable debt & financial difficulty in the English and Welsh Civil and Social Justice Survey. 4 Prevalence of debt/financial problems was not equally distributed, with younger respondents, those in receipt of benefits, those in rented accommodation, cohabitants and particularly, unemployed respondents, those with mental health problems and lone parents all far more likely to report problems. We agree with the Equality Impact Assessment conclusion that: There would be a number of positive impacts on the protected groups as a result of the strengthened consumer protections we propose to introduce, including prudential standards for debt management firms. Money Advice Trust April al_difficulty_in_the_civil_and_social_justice_survey.pdf