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

[EXC]

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

I could always ask Haris if you'd like.

[EXC]

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

Some responses to the Consumer Credit and Personal Insolvency Call For Evidence:

Building Societies Association Managing Borrowing and Dealing with Debt :: BSA - Building Societies Association

Consumer Financial Education Body http://cfebuk.org.uk/pdfs/consumer_c...20evidence.pdf

Money Advice Trust http://www.moneyadvicetrust.org/imag...20evidence.pdf

One of the case studies MAT quoted is really below the belt isn't it?

''Client told us that their bank has stated that they were exercising their right of set off to deduct payments from their bank account to pay towards a credit card. However, the bank would always take just under the minimum payment on the card. In doing so they would receive the majority of their money but would also charge the client for late payments to the credit card as the minimum payment had not been met.''

[EXC]

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

Some interesting data given by the BIS in response to a Parliamentary question about the Call for Evidence, even though they didn't actually answer the question.

Dr Creasy: To ask the Secretary of State for Business, Innovation and Skills how many submissions his Department received to his call for evidence on consumer credit and personal insolvency; and how many such submissions (a) referenced the need for steps to address the cost of credit and (b) called for a cap on the amount that can be charged for credit. [31970]

Mr Davey: As of 15 December the call for evidence has received 184 substantive submissions. The call for evidence closed on 10 December but to ensure we obtain all the evidence to enable us to make the best decisions for consumers and business, my Department has agreed to accept late submissions and these are still being received.

We have received 43 responses to the questions on an interest rate cap for credit and store cards and 56 responses that referenced interest rate caps on high cost credit products have been received. 53 responses to the questions on OFT’s review of high cost credit have also been received.

The call for evidence has so far received 1,740 individual e-mails that call for Government to introduce an interest rate cap on high cost credit products. Most responses were received towards the end of the call for evidence and my officials are in the process of carrying out detailed analysis of all the responses received.

House of Commons Written Answers 20 December 2010

[EXC]

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

John Fingleton is up before the Treasury Select Committee this Thursday to give evidence on their Competition & Choice in the Banking Sector inquiry.

Should be interesting.

[Amethyst]

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

http://www.competition-commission.or...t_order_hs.pdf

[EXC]

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

Some interesting figures from evidence given to the Treasury Select Committee by the Co-Op bank.

The committee has asked each and every bank what it costs them to run a current account and all but the Co-Op have claimed that they don't know. But the Co-Op said that the average annual cost per account is £85.

The OFT Market Study published a figure of appx 55m current accounts in the UK that yielded revenues of £8.3b. So using the Co-Op's costs, crudely calculated, banks would make about £4b profit from them at a margin of nearly 100%.

Uncorrected Evidence - HC 612-ix

[EXC]

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

Latest bulletin from Lending Code Standards Board.

http://www.lendingstandardsboard.org...Feb%202011.pdf

Not a single mention of opt-outs which to me indicates just how seriously (or not) they are taking it.

[EXC]

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

To be honest I don't blame them.

Their answers - especially to Q8 - would essentially be a self assessment of their own work which they can't really be expected to make public.

I'll FoI BIS for it along with the banks responses.

BIS have written asking for more time to consider the public interest test and I have responded as follows:



Dear Mrs Carpenter

Thank you for your response.

I write in regard to the delay to a substantive response to my request on the basis of further consideration of the public interest test.

I would remind you of an identical request I made in August 2010 (ref 10/1947) to which at least some of the information I requested was released notwithstanding the public interest test.

Therefore on the basis of precedence alone, I expect at least some of the information requested to be forthcoming.

To be clear, should I be dissatisfied with your final response I fully intend to ask BIS to conduct an internal review and, failing that, a complaint to the information commissioner.

Yours sincerely


I have got the consultation response from the BBA - attached.

The last paragraph of their response to Q8 reads:

''The BBA therefore strongly believes that changes already undertaken and those in the process of implementation mark a key change in the way that personal current accounts are operated and priced. We believe that the market should continue to be the driver of such changes rather than any arbitrary price caps.''

But even according to the preceding paragraphs it is clear that the initiatives have not been driven by ''the market'' at all but rather pressure from the OFT & LCSB. I really think this should be pointed out to BIS.

[EXC]

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

Dear xxx

Thank you for your email regarding the delay in providing you with a substantive response to your Freedom of Information request.

Every Freedom of Information request the Department for Business, Innovation & Skills receives is considered individually. The information which is identified as in scope of the request is considered carefully and is released unless it is identified that a prejudice is likely to be caused by such a release. Where a likely prejudice is identified and a qualified exemption of the Freedom of Information Act 2000 is engaged, the Department must balance whether the public interest lies with release of the information or withholding it. As indicated in my letter, Section 10(3) of the Freedom of Information Act 2000 allows public authorities additional time to complete this consideration.

Although this request may appear to be similar to your previous request, the information which falls within scope is not identical to information considered previously and we are therefore required to consider it on its own merits. We have already provided information regarding the British Bankers Association and HBOS and I expect to be able to respond regarding the rest of the information you have requested by 3 March.

Yours sincerely,

Mrs Valerie Carpenter

Valerie Carpenter | Assistant Director | Credit Market Regulation, Consumer and Competition Policy Directorate | Department for Business, Innovation & Skills

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

House of Commons Written Answer: Bank fees
Chris Leslie asked BIS, with reference to the Coalition Agreement, page 13, when they plan to bring forward proposals to end unfair bank and financial transaction charges.

Responding, Edward Davey, BIS Minister, stated:
''The Government have committed in the coalition agreement to introduce stronger consumer protections including measures to end unfair bank and financial transaction charges. We have been considering how best to take forward this commitment and believe that it should be done in the context of a wider strategic approach to strengthening and streamlining consumer protections and advocacy. This issue is therefore being addressed as part of our Consumer Credit and Personal Insolvency Review.''

''The Call for Evidence on this Review has now closed. We have received a considerable number of responses which we are now considering. If the evidence comes out in favour of action, we will not hesitate to act to protect the interests of consumers. We will come forward with specific proposals in spring 2011.''

[EXC]

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

This might be interesting.


Mon 28 Feb 2.30pm House of Lords - Lords Chamber


*Baroness Kramer

to ask Her Majesty’s Government what assessment they have made of the progress of the Independent Commission on Banking.

[EXC]

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

I've got the response to the FoI request for the responses to the consultation (BIS & HM Treasury Consumer Credit and Personal Insolvency Call for Evidence).

The responses are from:
Barclays
Lloyds
RBS
HSBC
FSCP
OFT

Many thanks to Enaid for getting it.

I'm a bit surprised we got the OFT's response as I'd previously asked the OFT for it directly but they refused saying that they thought it 'wouldn't be appropriate' to disclose it. Well we do, so here it is - albeit quite heavily redacted. Their response to Q8 (about bank charges) is about as lame as it gets.

EDIT having trouble uploading files so I'll try again after school run.

[EXC]

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

Citizens Advice Bureau's response to HM Treasury & BIS 'A new approach to financial regulation: Consultation on reforming the consumer credit regime'.

[EXC]

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

House of Commons Written Answer: Bank fees
Chris Leslie asked BIS, with reference to the Coalition Agreement, page 13, when they plan to bring forward proposals to end unfair bank and financial transaction charges.

Responding, Edward Davey, BIS Minister, stated:
''The Government have committed in the coalition agreement to introduce stronger consumer protections including measures to end unfair bank and financial transaction charges. We have been considering how best to take forward this commitment and believe that it should be done in the context of a wider strategic approach to strengthening and streamlining consumer protections and advocacy. This issue is therefore being addressed as part of our Consumer Credit and Personal Insolvency Review.''

''The Call for Evidence on this Review has now closed. We have received a considerable number of responses which we are now considering. If the evidence comes out in favour of action, we will not hesitate to act to protect the interests of consumers. We will come forward with specific proposals in spring 2011.''

I spot a small but encouraging change in the language the Government is using to response to MP's questions about bank charges. Note the 'If' in the response (highlighted above) of a few months ago and the 'will' in response to the same question this week:


House of Commons Written Answer: Bank charges
Gordon Banks (Labour Ochil and South Perthshire) asked HM Treasury if they will take steps to prevent excessive bank and financial transaction charges on unauthorised overdrafts. Responding, Mark Hoban stated:

''The Government have committed in the coalition agreement to introduce stronger consumer protections including measures to end unfair bank and financial transaction charges. This commitment is being taken forward as part of the joint Department for Business, Innovation and Skills and HM Treasury Consumer Credit and Personal Insolvency Review. Following a call for evidence, the Government are now considering the available evidence and will come forwards with specific proposals in due course.''

[Budgie]

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

Excellent, well spotted Exc !