BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

[leclerc]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

With regards to the charging scenarios, that is why they should send them out with the statements and/or with their changes to the T&C's. NatWest's current changes due in Feb next year did NOT include charging scenarios in spite of the fact that the main change was the charges themselves.

[EXC]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

The OFT themselves even conceded that they were difficult to find in their last PCA update:

''While we are pleased that banks have introduced charging scenarios, we
note that some are easier to locate online than others. Some require a
significant number of 'clicks' from the banks' homepage, while others
are not in what the OFT considers that a consumer would regard as an
obvious location. We would encourage strongly all banks to make
scenarios as easy to find as possible.''

http://www.oft.gov.uk/shared_oft/rep...ts/OFT1275.pdf

[Amethyst]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Dont know if we already have this posted

Consumer rights directive Industrial policy and tourism in Europe
On 18 November the Committee will
examine approximately 1,300 amendments
that have been tabled on the proposal for
a new consumers rights directive.
The Rapporteur and the shadow
rapporteurs are planning an active
timetable of meetings to make progress on
the proposal.
The IMCO vote will take place on 9
December 2010.


Think you can watch it See Hear
Amendments discussed can be found in docs starting http://www.europarl.europa.eu/meetdo...6/836026en.pdf (all a bit mind numbing)

http://www.europarl.europa.eu/meetdo...s_reich_en.pdf

[EXC]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

(all a bit mind numbing)

You're not wrong there. I lost the will to live after about 20 minutes.

Here's a few amendments that caught my eye before I slipped into a coma:


Amendment
(50a) Requiring a consumer to purchase
ancillary goods or services not advertised
in the price of the main contract should
be presumed to be unfair. Contingent
charges, such as penalties for breaching
the contract terms, should be presumed to
be unfair where they are clearly
disproportionate to the costs incurred by
the trader.


Amendment
(11) The existing Union legislation on
consumer financial services contains
numerous rules on consumer protection.
For this reason the provisions of this
Directive cover contracts relating to
financial services only in relation to unfair
terms in such consumer contracts and
allow for more stringent national rules to
be applied in that field.


Amendment
(49a) It will be presumed that clauses
providing for prices to be increased are
unfair if the consumer is not allowed to
withdraw from the contract in such an
event and the ultimate price is too high in
relation to the agreed price. This should
not, however, prevent tour operators from
altering contractually agreed prices
subject to the conditions stipulated in
Article 4 (4), (5) and (6) of Council
Directive 90/314/EC des Rates.

[EXC]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

From: EXC
Sent: 01 December 2010 08:59
To: Robert Skinner
Cc: Paul Smith
Subject: Re: Opt-out standards schedule[/font]


Hi Robert

Are you any wiser on the publication date yet?


Kind regards

Nick



From: Robert Skinner
To: EXC
Cc: Paul Smith
Sent: Wednesday, December 01, 2010 9:07 AM
Subject: RE: Opt-out standards schedule


Hi Nick, we are getting very close and I should be able to get back to you in a couple of days.

Kind regards

Robert

[EXC]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Should be interesting:

9 December IMCO will present 2 briefing papers: 1) The relation between the Consumer Rights Directive proposal and the area of Financial Services 2) Information requirements in the Consumer Rights Directive proposal and in other Directives, IMCO will also hold an exchange of views on the Single Market Act

[EXC]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

This is the briefing paper - The relation between the Consumer Rights Directive and the area of Financial Services.

http://www.europarl.europa.eu/docume...ATT01108EN.pdf

It's a tough read though.

[Amethyst]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

We have now submitted our response to this consultation.

Massive thanks to Tom and EXC for all the hard work they have put in to this, if someone didnt put the consumers view forwards, things would not change. It may only be a drop in a big ocean, but at least we can say we put a view forwards on behalf of consumers and are fighting for fairness in the future not just whinging about it from afar. Tom and EXC have worked extremely hard on responses on your behalf, particularly relating to bank charges and the future of personal current accounts, and the extremely luke warm changes proposed by the Lending Standards Board with regards to opt out of unauthorised overdraft charges.

You have a voice here, USE IT !

We'll put a copy of the main parts up later on.

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Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Beagle's response to the bank charges element of the consultation:




Do you believe that the current voluntary, market-driven initiatives to address concerns about unarranged overdraft charges are delivering, or will deliver, sufficient improvement for consumers? If not, what would the wider implication of limiting bank charges be?

The current voluntary, market-driven initiatives to address concerns over unarranged overdraft charges have been an abject failure, by each and every conceivable measure. They are incapable, in our view, of going any way towards addressing the serious concerns of consumers over bank charges.

We have previously expressed our concern at the attempts of the regulators to bring about reform of this area by way of voluntary, market-driven initiatives. In our experience, companies within the financial services industry are incredibly reluctant to take any steps which are contrary to their own economic interest. As has been noted before, there is little or no competition between the charging elements of bank accounts, and as such, they do not react to normal market forces, and are rarely, if ever, the basis of informed consumer choice. Given the relentless pursuit of short-term returns and high-yield profits by all of the UK banks, it was naive in the extreme to believe that market-driven initiatives were going to be in any way effective. To pursue anything other than tight regulatory control over the levels and incidence of bank charges would, in our view, be a deliberate failure on the part of the Government to prevent the relentless profiteering by the banks from the misfortune of the most vulnerable consumers.

We would stress at this stage that it is impossible to overstate the impact of bank charges on our members and consumers as a whole. We have specific cases where families have been unable to pay for basic food and necessities, have witnessed members face repossession proceedings, or the prospect of bailiffs disposing of their personal possessions. The distress that has been caused as a direct result of these charges has been very real, and must be considered in the light of the total disregard of any of the banks involved to act in a reasonable manner, or to take steps to reduce the financial hardship which they cause and compound. We have, time and again, been amazed at the complete lack of compassion or humanity of those banks that have been involved with these distressing cases. It is for these reasons that we could not have any faith in any market-driven initiatives in the area of bank charges.

The failure of these initiatives is demonstrated by a number of factors: a lack of transparency & consumer comprehension, current costs of charges, lack of consumer control, and the invidious cycle of debt. We deal with each of these in turn below.

Consumer Comprehension/Transparency
As noted in our main submission, it is our experience that consumer comprehension of the true cost of their bank account is remarkably low. We put this down to a combination of factors; including complexity of charging structure, continuous fluctuation of the amount in a current account, lack of expertise, the opaque manner in which charges can be applied and ever-changing charging formulas.

Following a review by the OFT into the personal current account market, steps were meant to be taken by the banks to make their charging structures clearer. To this end, certain charging scenarios were developed as an educational tool for consumers. A recent request made under the Freedom of Information Act to the OFT revealed that consumers were not making as much use of these charging scenarios as was envisaged by the conclusions of the market study. As at 15 November 2010, fromthe time of the introduction of the Charging Scenarios (the deadline for the largest banks was 30 June 2010) to October 2010 this year there were just 21,152 visitors to the Charging Scenarios website pages of the seven largest UK banks, which amount to less than 0.05% of consumers with a bank account. The Charging Scenarios from the Consumer Direct page went live on 8 July 2010, and there have been just 261 visitors ('hits') to it since it was created. In it’s most recent update the OFT suggested that the charging scenarios are not as easy to find on the banks website as they should be. We would go further; these charging scenarios are difficult to locate, and when they are located, they are far too complex, because the processes on which they are based are in themselves too complex.

As revealed in the OFT’s PCA Market Study the largest element of cost to consumers for personal current accounts is forgone interest (banks use the term ‘net interest income’ – the difference between interest paid and interest achieved on credit balances) which accounts for 50% of banks’ revenue from PCAs. It is this significant cost that was responsible for the OFT concluding that the ‘free if in credit’ banking model is a myth. But nowhere is this cost referred to in any bank’s literature and for consumers calculating this cost is very difficult.

To illustrate this point, when questioned by the House of Commons Treasury Select Committee on 23 November 2010, the Chair of the Financial Services Authority on 7 December 2010, Lord Turner, admitted that he did not know the actual cost to him of his personal current account. Subsequent evidence to the same Committee on 7 December 2010 from Helen Weir, head of retail banking at Lloyds TSB, indicated that in her view “...customers have a pretty good idea of what they are paying [for their bank account]”. But when questioned about how much she was paying for her own personal bank account, she was unable say. Both Lord Turner and Helen Weir must be considered expert witnesses within this field, and they had both come prepared to present evidence to the Select Committee on the subject of personal current accounts, particularly the charging structure. Given their inability to judge how much they themselves were paying for their bank account, we would simply observe that if someone with this level of expertise does not know the cost, and therefore the value, of an important financial service, then it is unrealistic to expect the average consumer to know the true cost of such a service. Indeed, we would echo the words of Andrew Tyrie, Chairman of the Select Committee, who put it to Helen Turner of Lloyds TSB: “You expect customers to have a pretty good idea. But you don’t know and you are chief executive.” That position, he added, was “ludicrous”.

Cost
Again, quoting Lord Turner in his oral evidence session before the TSC on the subject of the remit of the future retail banking regulator, he said that ‘’..... the answer is, when and if all that is tidied up, yes, I do think the appropriate regulatory authority should be directly looking at both the transparency and indeed the level of unauthorised overdraft charges. That should be part of our regulatory machinery.’’

We believe that the best indicator of whether bank charges are becoming fairer is in the overall cost to consumers. The latest evidence from the OFT, published in ‘Personal current accounts in the UK: Progress update’ in September 2010, is that the level of bank charges taken from consumers has remained at similar levels since 2006 when the investigation began:

Revenue from Unarranged Overdraft Charges

2006 £2.54 billion
2007 £2.48 billion
2008 £2.76 billion
2009 £2.52 billion

These figures are, to our mind, quite staggering. All the available evidence suggest that the cost to the bank of a consumer going into an unarranged overdrafts is less than £2.50, with the vast majority of instances costing the bank almost nothing, according to the OFT. We note that whatever costs there might be involved to the bank, these are likely to be easily covered by the higher interest rates that are imposed on unauthorised overdrafts, which are as high as 30% interest p.a.

Levying £2,500,000 annually in unexpected, unwanted, and often concealed charges on the most vulnerable consumers is, to our mind, nothing short of extortion. The consumers afflicted by these charges get little or nothing in exchange. To say that these charges offer little value for money is to miss the point: when something is taken unexpectedly and without your informed consent, many of our members would categorise such conduct as akin to theft rather than the provision of a service.

Despite the outcry and widespread condemnation of these charges, the impact on their use has been negligible – which in itself suggests that they are unavoidable. The banks still see them as a legitimate and useful form of profits, with little regard for the impact on consumers or on the market as a whole. The figures above clearly indicate that the market-based initiatives have failed. The time for regulatory intervention is as pressing today as it was in 2006. That consumers have had to wait this long for any sort of action is a damning indictment of both the regulators and the Government that have failed to take the obvious and necessary steps. The injustice of this regulatory inaction has been compounded by the financial crisis brought about by the banks and the subsequent recession. To our mind, it is a matter of great shame that the very financial institutions that have taken so much from consumers should have been bailed out by the Government without any concessions from those banks as to the manner in which they treat consumers in turn. As the impact of the austerity measures brought on by the financial crisis hits home over the coming months, we would remind the Government that the banks do not get to vote in elections; but consumers do.

Lack of Consumer Control
As noted by the OFT, current accounts are the gateway to the consumer markets. In particular, the near-universal practice of depositing a salary or other income into a current account and then using those funds by way of debit card, cash withdrawals, cheques, direct debit or standing order is the norm for the vast majority of consumers in the UK. Bank accounts are integral to 21st Century life, and in that respect, can be considered a utility – and should be regulated as such. Latest figures indicate that over 93% of adults in the UK hold at least one bank account, and the experience of our members suggests that the majority of consumers would consider a bank account a necessity.

In this respect, it is surprising how little control a consumer will have over the manner and frequency with which bank charges are levied. The reality of day to day life is that consumers are unlikely to know exactly how much money is in their current account. Whilst we do not abdicate consumers of their responsibility to ensure there are adequate funds in their account, we must recognise that humans do not have the accuracy or attention of computers and computer programmes dedicated to monitoring the credits and debits of a bank account. Errors will inevitably occur, either through poor planning or through unexpected events. We do not believe that this entitles the banks to take advantage when such errors do occur.

The average consumer needs a bank account, and historically there has been little difference between the standard terms of the various banks, particularly in respect of charging structures and charging levels. Furthermore, the balance of power would inevitably be shifted towards a company who has access to, and a great level of control over, a consumer’s finances, through loans, overdrafts, and charges which can appear to be discretionary. In particular, a bank can alter any arranged overdraft as it sees fit (subject to notification), and a frequent problem has been where a consumer’s overdraft facility has been unilaterally lowered by the bank, which the consumer is unable to reduce, and which results in additional charges being levied.

Bank charges are particularly onerous as they give the banks priority over the consumer’s other debtors with regards to the application and payment of the charges to the account, and as such give rise to a serious imbalance due to a complete lack of control by the consumer. The consumer has no control as to when or how the charges are paid, as they are automatically taken from the account. The consumer has no means to “opt-out” of the charges once they have been incurred. The consumer has no means of prioritising their essential bills over the charges.

It should be noted that benefits and pensions are normally protected from any form of assignment. The legislation is designed to protect the recipient from themselves and/or unscrupulous third parties, so as to ensure a minimum income for the intended recipient to meet their basic needs (the purpose for which the payment is intended). However, once such benefits are paid into a current account, they no longer come under statutory protection, and the banks are able to access them by way of charges without any concern for the basic needs of the intended recipient.

This lack of effective control has lead, in our view, to an abuse of economic power by the banks. We urge the Government to take the necessary steps to prevent this state of affairs from continuing.

Cycle of Debt
One of the biggest criticisms from consumers, and one of our greatest concerns in respect of these bank charges, is the fact that they can and do create a cycle of debt from which the consumer cannot escape. The term “crippling” is often used by consumers to describe the nature of the charges. If a consumer is in financial hardship and receives charges as a result, then the consumer is more likely in the following month to be unable to maintain the account within the agreed overdraft facility and will receive further charges as a result. In some cases, the amount of charges in any given month could easily exceed the amount of benefits coming into the account.

The level and incidence of charges imposed on some consumers results in a vicious cycle of debt from which they simply cannot escape. Due to a poor credit rating and an overdrawn account, the consumer will be unable to transfer their existing overdraft facility to another bank, and are to all intents and purposes locked into their current bank, even when the consumer no longer wishes to remain with that bank due to the poor value for money that their services provide. In our experience, it does not occur to many consumers that they can have a second account with another bank and pay their salary or benefits into that account so as to ‘protect’ their income from these crippling charges. Even where a consumer does opt to open a new account with a different bank, the charges will continue to be imposed on the ‘old’ account and the consumer will be pursued for the outstanding amount. A little know term in all standard banking contracts prevents the customer from closing the account while it is in debit and locks the consumer in to incurring repeated charges – often daily.

In any event, this cycle of debt can often result in severe financial hardship for the consumer, who can be made bankrupt, have their home subject to possession proceedings or have their personal possession subject to bailiff action.

Aside from the aforementioned legal action that is taken against a consumer trapped in a cycle of debt, there is the hardship which can be faced on a day to day basis. Even a cursory browse of consumer forums will show a plethora of cases where the consumer cannot pay for basic food and necessities. The level of stress that this can produce, particularly where the consumer has children to care for, really must be experienced to be believed.

Whilst consumers must ultimately have responsibility for their own financial situation, there is a strong argument that consumers must be protected from the banks’ sharp practices of trapping them into a cycle of continuous excessive charges. The banks have made huge profits from exploiting the financial hardship of consumers; the best estimates we have obtained puts that figure at well over £25billion since the introduction of the Unfair Terms in Consumer Contract Regulations 1993.

Opt-outs.
As one of the major initiatives in addressing outstanding concerns relating to personal current accounts (PCAs) and in particular unauthorised overdrafts, the OFT announced in March 2010 that after consultation with the industry, it had agreed in principle to develop best standards to cover how consumers are offered the ability to opt out of incurring unauthorised charges.

This work has been led by the Lending Code Standards Board (LCSB) which has recently established the standards which are to be incorporated into the Lending Code and come into effect in April 2011.

Firstly, it is important to understand exactly what it is that consumers would be able to opt out of.

During the bank charges test case litigation it was established that bank charges are, in the main, for the service of ‘consideration’ of whether to grant an unauthorised overdraft or not where a payment instruction has been made when there are insufficient funds to meet it. The banks by default, ‘deem’ a payment instruction in those circumstances as an ‘informal request’ for an overdraft regardless of the customer’s true intent. There is no option for the customer to present a payment instruction without it also being deemed as an overdraft request. Indeed, no payment instruction exists that actually states that it is also a request for an overdraft, either expressly or implicitly. That the banks deem it as such is entirely presumptuous on their part and takes no account of the customer’s actual wishes. This was the banks’ pleaded position, accepted by all three courts. The charges are not for the provision of the overdraft itself, for which there is an associated interest charge. The service of ‘consideration’ is uniquely compulsory.

We would note, however, that these automated ‘requests’ occur without any human interaction from either the customer or the employees of the bank. In contrast, where a consumer does have a face to face meeting with an employee of the bank to request an overdraft, there is no charge levied, regardless of the outcome of that request. It is clear, in those circumstances, that the informal request for an overdraft which is deemed by the bank to have occurred as a result of an electronic instruction is nothing more than an artificial construct, used as an excuse to levy automated charges for a non-existent service. We believe that this artificial construct should have no place in modern banking law. In an age of instantaneous communication, by way of text message, phone call or email, there should be no scope for “deemed” requests when no such request is being intentionally made.

In any event, the vast majority of PCA holders do not make use of this artificial ‘consideration’, since they do not go over any overdraft limit, if they go into overdraft at all. The OFT PCA Market Study suggests that some 80% of account holders do not incur any unauthorised overdraft charges. Of the remaining 20% who incur such charges - unknowingly, unwillingly or otherwise - only a very small proportion actually want it. A large poll of 5952 people conducted by MoneySavingExpert found that 92% of people would prefer a payment instruction to be refused without charge rather than have that instruction considered for payment for a fee.

We believe that the entire concept of an opt-out scheme for bank charges is distorting the reality of the situation, given that less than 2% of consumers genuinely want the service. We are of the view that even if the proposed scheme were capable of having an impact, that it should be an “opt-in’ scheme, rather than an opt-out scheme.

It is our view that the ‘opt-out’ proposals are wholly inadequate, and will not bring about the necessary changes to the market. The reasons for this are all too clear: first, the opt-out is purely voluntary on the part of the banks; second, the opt-out covers only a minority of such deemed requests, leaving the bulk of unauthorised overdraft charges – particularly unpaid item fees and monthly fees – untouched and unaffected.

More specifically, the LCSB’s opt-out standards only allow for opting out of the provision of an unauthorised overdraft and not the ‘consideration’ of it and as such does not address the mischief for which it is intended, since going into unauthorised overdraft cannot be avoided in numerous circumstances, not least when an unpaid item fee is incurred. Therefore the unpaid item charge that is otherwise levied for the service of ‘consideration’ is still made even though the opt-out pre-determines that no ‘consideration’ is either required or will take place.

The opt-out standards provide that:

‘’If a customer has elected to opt out then items presented that would, if paid, cause an unarranged overdraft, will be returned unpaid and may be subject to a unpaid item charge. Overdrafts resulting from the payment of the items set out in 2.1.1 above will be treated as unarranged and the provider’s normal charges may apply.’’

Clearly the opt-out standards are self defeating by virtue of unpaid item fees which form a significant portion of bank charges as a whole; according to the OFT PCA Market Study unpaid item fees, where the provision of an unauthorised overdraft is refused (but necessarily also results in an unauthorised overdraft and in turn an additional fee), account for 42% of the industry revenue derived from insufficient funds charges (£1bn of £2.4bn).

In our view, due to the implementation of opt-out standards, the revenue generated by unpaid item fees (and the level of consumer detriment) will only increase.

In short an opt-out means the benefit of any fee avoided by a payment instruction that would otherwise incur an unauthorised overdraft charge would be negated by the resultant unpaid item charge. In addition the requirement on providers to offer accounts with an opt-out facility is entirely voluntary and accounts which would offer an opt-out facility would have no overall benefit in respect of insufficient funds charges than basic bank accounts already in existence.

Coupled with historically low switching rates - even between different account products with the same provider - it is difficult to understand how the opt-out initiative can genuinely provide sufficient improvements for consumers.

Conclusion
We fully support the Government in its intention to ensure that charges are fair, clear and proportionate for consumers and banks, and we consider the pledge made in the Coalition Agreement to end unfair bank and financial transaction charges to be a litmus test of how committed this Government is to protecting consumers.

Whilst the abolition or strict control of bank charges will inevitably have a consequence on the charging structures for bank accounts, the benefit to consumers as a whole would increase. Firstly, vulnerable consumers will face fewer unexpected and unwarranted charges, thus reducing the disproportionate costs that these consumers carry in operating the retail banking sector as a whole; and secondly, the costs involved in operating current accounts will be made more transparent, by way of up-front fees or interest rates, which consumers will find much easier to compare and contrast. In addition, this will make the retail banking industry more competitive as a whole.

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Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Lenders want to charge for accounts

By Sharlene Goff
FT Online

Published: December 14 2010 02:50 | Last updated: December 14 2010 02:50


Banks privately embrace the idea of charging for current accounts but the fear of losing customers means none is prepared to be the first to scrap the existing free banking model, according to Martin Taylor, former chief executive of Barclays.

In the last of the Question Time-style debates organised by the government-appointed Commission on Banking as part of its 15-month probe into the industry, Mr Taylor, a member of the commission who chaired the event, said: “Bankers privately would love to move away from the untransparent cost structure” of current accounts.

The meeting on Monday capped off five public events that took place around the UK to gauge consumer and business experiences of the banking industry.
After three general events in Leeds, Edinburgh and London, and a debate focused on the banking needs of small and medium-size enterprises in Cardiff last week, the final session focused on consumer banking and, crucially, the competitiveness of the British banking sector.

The level of concentration in the UK retail market is one of two key areas of focus for the commission, along with the broader issue of banks’ stability.

The commission will look particularly closely at the dominant share of current accounts held by Lloyds Banking Group following its takeover of HBOS. The discussion followed calls from Lord Myners – who, as City minister in the last government, played a key role in the financial bail-outs at the height of the global crisis – to boost competition by splitting up big high street banks such as Lloyds and Royal Bank of Scotland.

Mr Taylor said he was particularly struck by an idea from a consumer organisation to impose public service demands on dominant banks. This could involve forcing them to offer better services to low earners or contributing to financial education.

Monday’s event kicked off with a discussion on how willing consumers are to switch their current account from one bank to another. When asked whether they would move provider in the next two years, almost 70 per cent of the London-based audience said it was at best unlikely.

Martin Lewis, founder of consumer website MoneySavingExpert.com, who was also on the panel, said this “apathy, ignorance and inertia” were the biggest contributors to bank profits.

The comments will fuel the debate over whether the opaque charging structure of current accounts limits competition and makes consumers less likely to shop around.

Mr Taylor said he would look particularly closely at how difficult it was for people to switch accounts if they had low credit scores.

FT.com / UK / Business - Lenders want to charge for accounts

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Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Martin Lewis | Should big banks have an ENFORCED public service remit?

[Amethyst]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

Mr Taylor said he was particularly struck by an idea from a consumer organisation to impose public service demands on dominant banks. This could involve forcing them to offer better services to low earners or contributing to financial education.

good, though I'd go with utilities than public services personally (or is that the same thing?)


I disagree with abolishing as and when charging structures and introducing fee paid accounts, as they would still have to have an element of as and when pricing on top.

BUT bouncing DDs/POS transactions should be free and you should be able to chose to have everything bounced or chose to incur fees for paying over your limits. Hence the opt out arguments and the pigs dinner the LSB are making of the main solution.

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Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

I think a utility is defined by it's public service remit so pretty much the same thing.

I totally agree with your view on charging. The danger is that we'll end up with a combination of both fee paying accounts and as and when charges - hold on! That's what we have now.

Re LCSB shall I send them the opt-out section of our BIS response? I think we should.

[Amethyst]

Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

I do, I still don't think it was accidental he sent it just before the BIS consultation was due in, he sounded much more positive on the phone so guess the ideas been stamped on by the banks as what he's come up with is no bloody different to how things are now.

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Re: BIS & HM Treasury Consumer Credit and Personal Insolvency Review - Consultation

I do, I still don't think it was accidental he sent it just before the BIS consultation was due in, he sounded much more positive on the phone so guess the ideas been stamped on by the banks as what he's come up with is no bloody different to how things are now.

The banks 'sponser' the LCSB.

When I went to his office their was a picture of Angela Knight on the frickin wall. Although their (very swish) offices are on the 17th floor, you look out the window and see Canary Wharf and all the banks' sky scrapers towering down on you and it just perfectly symbolises the banks' dominance over them.