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Originally posted by BBA
Closing your account
7.6 Under normal circumstances, we will not close your account without giving you at least 30 days’
notice. Examples of circumstances which are not ‘normal’ include threatening or abusive behaviour
towards staff.
Subscribers will be able to respond to a bankruptcy notice by immediately closing an account without notice if they feel
this is necessary. Similarly, they may respond to a request by a receiver in bankruptcy to close an account and send the
funds to the receiver under his powers which are not compromised by the Code.
7.7 We will not close your account, or threaten to do so, as a response to a valid
complaint you have made.
Subscribers should not close an account solely because a customer has made a complaint or exercised their rights
under the Banking Code or in law, so long as the customer is not also acting in a manner that might normally lead to
account closure.
7.6 Under normal circumstances, we will not close your account without giving you at least 30 days’
notice. Examples of circumstances which are not ‘normal’ include threatening or abusive behaviour
towards staff.
Subscribers will be able to respond to a bankruptcy notice by immediately closing an account without notice if they feel
this is necessary. Similarly, they may respond to a request by a receiver in bankruptcy to close an account and send the
funds to the receiver under his powers which are not compromised by the Code.
7.7 We will not close your account, or threaten to do so, as a response to a valid
complaint you have made.
Subscribers should not close an account solely because a customer has made a complaint or exercised their rights
under the Banking Code or in law, so long as the customer is not also acting in a manner that might normally lead to
account closure.
Originally posted by BBA - Financial Difficulties
14 Financial difficulties – how we can help
14.1 We will be sympathetic and positive when we consider any financial difficulties you may have. Our
first step will be to try to contact you to discuss the matter.
This spells out existing good practice. Subscribers will consider customers to be in financial difficulty when income is
insufficient to cover reasonable living expenses and meet financial commitments as they become due. This may result
from a change in lifestyle, often accompanied by a fall in disposable income and/or increased expenditure, such as:
• loss of employment
• disability
• serious illness
• imprisonment
• relationship breakdown
• death of a partner
• starting a lower paid job
• parental/carer leave
• starting full-time education
A customer’s financial difficulties may become evident to the subscriber from one or more of the following events:
• items repeatedly being returned unpaid due to lack of available funds;
• failing to make loan repayments or other commitments;
• discontinuation of regular credits;
• notification of some form of insolvency or court proceedings;
• regular requests for increased borrowing or repeated rescheduling of debts;
• making frequent cash withdrawals on a credit card at a non-promotional rate of interest; and
• repeatedly exceeding a credit card or overdraft limit without agreement.
If during the course of a customer’s account operation a subscriber becomes aware, via their existing systems that the
customer may be heading towards financial difficulties, the subscriber should contact the customer to outline their
approach to financial difficulties and to encourage the customer to contact the bank if the customer is worried about
their position. Subscribers should also provide signposts to sources of free, independent money advice.
Subscribers will determine the level of intervention required dependent on the individual customer’s position.
Subscribers should make available to customers straightforward information in plain English on their procedures and
systems for dealing with customers in financial difficulty. This might explain, for example, the main rights and
responsibilities of customers and subscribers, and what is involved in legal demands or a referral to a debt recovery unit.
The BBA publishes a leaflet, ‘Dealing with Debt’ which is available on the BBA, BSA and APACS websites (see inside
front cover of this Guidance for website addresses).
14.2 If you find yourself in financial difficulties, you should let us know as soon as possible. We will do all
we can to help you to overcome your difficulties. With your co-operation, we will develop a plan with
you for dealing with your financial difficulties and we will tell you in writing what we have agreed.
Subscribers will try to assist customers in financial difficulties. The subscriber will not usually be aware that the
customer’s circumstances have changed until the customer tells them.
Where a customer requests that the subscriber deals with them in writing or e-mail (providing that facility is available)
rather than by telephone, they will do so as long as the customer remains co-operative and in regular dialogue.
There is also an onus on customers to try to help themselves. These requirements do not mean that the commercial
judgement of subscribers is compromised.
If a customer does not respond to direct attempts to re-establish contact, lenders may pursue other alternatives to
establish a point of contact. This may include the use of debt collection agencies and tracing agents (see section 14.6).
14.3 The sooner we discuss your problems, the easier it will be for both of us to find a solution. The more
you tell us about your full financial circumstances, the more we may be able to help.
If it becomes clear to the subscriber that the customer needs specialist assistance, the customer should be referred
promptly to a specialist team that deals with customers in financial difficulties, if one exists. In some cases, referral to a
debt recovery unit may also be necessary.
The subscriber should explore a range of options with the customer. Usually this will require the customer to disclose to
the subscriber details of their income, expenditure, assets and liabilities, including amounts (if any) owed to other
creditors. This information will be used to develop a plan for dealing with the liabilities. In cases where there are liabilities
to multiple creditors, subscribers should recommend a free money advice service (see section 14.4).
The initial arrangements for repaying the debt should be in writing or other durable medium. This will not always be
treated as a formal debt management plan, and there may be departures from this plan, if it is in the interests of
subscribers and customers. There is no need for every small departure from the basic plan to be in writing (for example
an agreement to accept a lower repayment for one week), but any amendments that change the fundamental nature of
the plan should be in writing. If, at the subscriber’s discretion, the plan includes an agreement to accept smaller
repayments, the subscriber should tell the customer whether this is regarded as ‘falling behind with repayments’ and
whether information will be passed to Credit Reference Agencies.
If the customer does not co-operate with the subscriber, a plan cannot be developed and the subscriber may proceed
with normal debt recovery procedures. Lack of co-operation would include not responding to the subscriber’s attempts
at contact and unreasonable demands by the customer (for example, a request that the debt be written off or repaid
over a very long period, even though the customer could afford to make reasonable repayments).
The subscriber should take into account any other accounts that the customer may have with the subscriber if these
have a credit balance. In addition, if a customer has assets which could reasonably be expected to be sold to reduce
outstanding debts, the subscriber may request that the customer, and if appropriate, their adviser, considers this option.
Thereafter, the subscriber should acknowledge that income should only be used to repay ‘non-priority’ debts once
provision has been made for any ‘priority’ debts. The subscriber should leave the customer with sufficient money for
reasonable day-to-day expenses, taking into account individual circumstances. Subscribers will not subject customers to
harassment or undue pressure when discussing their problems.
A debt is considered ‘priority’ where the customer’s failure to pay could lead directly to the loss of one or more of the following:
• the customer’s home (e.g. rent, mortgage, secured loans);
• their liberty (e.g. council tax, child support maintenance, income tax, court fines);
• their utility supplies (e.g. water, gas, electricity); or
• their essential goods or services (e.g. a cooker, a fridge, or the means to travel to work).
Subscribers should consider appropriate concessions, relating to charges and interest payable by the customer, where
the customer is constructively cooperating with the subscriber. Considerations might include reducing or suspending
interest, charges and fees where agreed repayments do not cover them. The nature of any concessions will need to be
assessed on a case-by-case basis, taking account of the seriousness of the customer’s situation. (Charges will have
been communicated to the customer under section 5 of the Banking Code.)
Token offers may be accepted where the customer has demonstrated they have no surplus income available for their
‘non-priority’ creditors and there is a realistic prospect of the customer's circumstances improving. A token offer will not
necessarily be sufficient to prevent the subscriber from selling the debt to a third party debt recovery agent and to
prevent the debt from being registered as a default with the credit reference agencies.
Where the subscriber considers the customer’s personal and financial circumstances to be exceptional and unlikely to
improve, the subscriber may, among other options, consider writing off or not pursuing part or all of the customer’s
debt(s). Where write-off is requested by a customer or adviser but is not considered appropriate by the subscriber, the
subscriber must give their reasons in writing. If the subscriber agrees to a write-off, then the debt may be registered as a
default with the credit reference agencies.
Repayment plans between subscribers and customers may be subject to regular review. Any review period will be
agreed with the customer or their adviser, and subscribers should seek to revise contributions only at the end of the
review period or if a customer’s personal circumstances change. (Customers and/or their advisers should inform the
subscriber if the customer’s personal situation changes.)
14.4 If you are having difficulties, you can also get help and advice from debt-counselling organisations.
We will tell you where you can get free money advice. If you ask us to, we will work with debtcounselling
organisations, such as Citizens Advice, money advice centres or the Consumer Credit
Counselling Service. Their contact details are as follows.
• Advice UK – 020 7407 4070 (adviceUK : Advice UK Homepage)
• Citizens Advice bureaux – You can get the phone number of your local bureau from the phone
book, the local library or www citizensadvice.org.uk
• Citizens Advice Scotland – 0131 550 1000 (The website of the Citizens Advice Bureau Service in Scotland
)
• Consumer Credit Counselling Service – 0800 138 1111 (CCCS - Free Debt Advice from the UK's Leading Debt Charity
)
• Money Advice Scotland – 0141 572 0237(Money Advice Scotland Online)
• National Debtline – 0808 808 4000 (National Debtline, for FREE CONFIDENTIAL and INDEPENDENT ADVICE call 0808 808 4000)
• Payplan – 0800 917 7823 (Free Debt Management company | Debt Advice | Payplan)
You should also be aware that there are other companies that charge a fee for managing your debts.
It is your responsibility to check the fees that may be charged before asking these companies to act
on your behalf.
This paragraph formally acknowledges the role of money advisers. Subscribers should tell customers where they can get
free money advice when the subscriber thinks the customer is in financial difficulties. Subscribers may give customers
time to consult a money adviser (this would not prevent subscribers protecting their position if necessary), and will be
prepared to enter dialogue with a money adviser when an appropriately completed authority to disclose information has
been received, either by fax or post (original or photocopy).
Subscribers will also work with a nominated adviser from an organisation not listed in section 14 of the Code, unless
they have reasonable grounds for believing that it would not be in the customer’s interests.
Communications with customers and/or their advisers should, wherever possible, acknowledge and reflect any previous
discussions that have taken place. Subscribers should be willing to communicate with customers and/or their advisers
by phone, post or fax. Normally, the subscriber will communicate through the adviser, if an authority has been received.
This does not preclude subscribers from copying correspondence to customers if they choose. In certain circumstances
it may be beneficial for discussions (either face-to-face or over the telephone) between the adviser and subscriber to
take place with the customer present.
On occasions the subscriber may need to contact the customer directly, even when an authority is in place. These
occasions may be the result of the adviser not being available, failing to provide requested information within a
reasonable period of time, or other similar circumstances.
Subscribers should give a phone number on all communications that will put the customer in contact with a named
person or a team dedicated to dealing with cases of financial difficulty.
14.5 If you have debts with many creditors, a debt-counselling organisation may complete a Common
Financial Statement (or an equivalent statement we accept) on your behalf, which we will accept as
the basis for negotiations with you in drawing up a debt-management plan.
This provision is designed to help people in financial difficulties, and some subscribers may only apply it when accounts
have gone into default. Other subscribers may choose to use the provision at an earlier stage if it benefits both them and
the customer.
Money advisers will use the BBA/MAT/FLA Common Financial Statement format and principles when submitting
information to subscribers5.
Subscribers should accept the Common Financial Statement (CFS) (and other similar statements such as that used by
the Consumer Credit Counselling Service (CCCS)). The CFS – or equivalent details of the customer’s income,
expenditure and assets – is necessary to enable the subscriber to gather information to assess if an ‘offer to pay’ will
enable the customer to be accepted onto a formal debt management plan (DMP), or enable the subscriber to reduce or
suppress interest and fees.
The third party money adviser should ensure that their authority to act on behalf of the customer is promptly sent to all
creditors identified by the customer. It is also the responsibility of the adviser to ensure that a CFS or equivalent is sent
to the creditors shortly after the authority. In these circumstances, where a money adviser has been appointed and there
are debts with many creditors subscribers will not normally be able to work with the customer until a CFS or equivalent
has been received.
In general, subscribers should then be prepared to accept an offer of repayment which is based on the principle of
equitable distribution of available income (after priority payments), in line with the amount outstanding to each creditor.
Alternative means of calculating the distribution of available income by the customer or their adviser may be agreed on a
case-by-case basis. A subscriber may accept an offer of payment, even though the offer is not sufficient to enable the
customer to be accepted onto a formal DMP.
14.6 In certain circumstances we may pass your debt to another organisation or debt-collection agency. When
arranging how you will make your repayments, we will always choose reputable firms which agree to follow
the Code.
Subscribers should follow a due diligence process when selecting third parties for debt management, which should
include third party compliance with Data Protection legislation, Consumer Credit legislation, Office of Fair Trading
guidance on debt collection and debt management, and the code of the Credit Services Association.
Subscribers should use all reasonable endeavours to ensure that the Code standards for handling financial difficulties
contained in section 14.1 of the Code are applied by such agents. Code compliance standards should form part of all
third party contracts agreed on or after 31st March 2002. Subscribers should pass on relevant information to enable the
third party debt manager to recover the debt.
14.7 In other circumstances we may sell your debt. We will always choose reputable firms if we do this.
Subscribers should follow a due diligence process when selecting any third party for debt sale. Any new contract
entered into after March 2005 with such companies should ensure that the third party will comply with Data Protection
legislation, Consumer Credit legislation, Office of Fair Trading guidance on debt collection and debt management, the
code of the Credit Services Association and the Banking Code’s standards for handling financial difficulties contained in
paragraph 14.1 even if the debt purchaser is not a subscriber. The subscriber will inform the third party of any relevant
arrangements currently being complied with by the customer.
It is common practice for third parties taking on a debt to request a new statement of income, expenditure and assets to
understand the customer’s most up-to-date position.
14.1 We will be sympathetic and positive when we consider any financial difficulties you may have. Our
first step will be to try to contact you to discuss the matter.
This spells out existing good practice. Subscribers will consider customers to be in financial difficulty when income is
insufficient to cover reasonable living expenses and meet financial commitments as they become due. This may result
from a change in lifestyle, often accompanied by a fall in disposable income and/or increased expenditure, such as:
• loss of employment
• disability
• serious illness
• imprisonment
• relationship breakdown
• death of a partner
• starting a lower paid job
• parental/carer leave
• starting full-time education
A customer’s financial difficulties may become evident to the subscriber from one or more of the following events:
• items repeatedly being returned unpaid due to lack of available funds;
• failing to make loan repayments or other commitments;
• discontinuation of regular credits;
• notification of some form of insolvency or court proceedings;
• regular requests for increased borrowing or repeated rescheduling of debts;
• making frequent cash withdrawals on a credit card at a non-promotional rate of interest; and
• repeatedly exceeding a credit card or overdraft limit without agreement.
If during the course of a customer’s account operation a subscriber becomes aware, via their existing systems that the
customer may be heading towards financial difficulties, the subscriber should contact the customer to outline their
approach to financial difficulties and to encourage the customer to contact the bank if the customer is worried about
their position. Subscribers should also provide signposts to sources of free, independent money advice.
Subscribers will determine the level of intervention required dependent on the individual customer’s position.
Subscribers should make available to customers straightforward information in plain English on their procedures and
systems for dealing with customers in financial difficulty. This might explain, for example, the main rights and
responsibilities of customers and subscribers, and what is involved in legal demands or a referral to a debt recovery unit.
The BBA publishes a leaflet, ‘Dealing with Debt’ which is available on the BBA, BSA and APACS websites (see inside
front cover of this Guidance for website addresses).
14.2 If you find yourself in financial difficulties, you should let us know as soon as possible. We will do all
we can to help you to overcome your difficulties. With your co-operation, we will develop a plan with
you for dealing with your financial difficulties and we will tell you in writing what we have agreed.
Subscribers will try to assist customers in financial difficulties. The subscriber will not usually be aware that the
customer’s circumstances have changed until the customer tells them.
Where a customer requests that the subscriber deals with them in writing or e-mail (providing that facility is available)
rather than by telephone, they will do so as long as the customer remains co-operative and in regular dialogue.
There is also an onus on customers to try to help themselves. These requirements do not mean that the commercial
judgement of subscribers is compromised.
If a customer does not respond to direct attempts to re-establish contact, lenders may pursue other alternatives to
establish a point of contact. This may include the use of debt collection agencies and tracing agents (see section 14.6).
14.3 The sooner we discuss your problems, the easier it will be for both of us to find a solution. The more
you tell us about your full financial circumstances, the more we may be able to help.
If it becomes clear to the subscriber that the customer needs specialist assistance, the customer should be referred
promptly to a specialist team that deals with customers in financial difficulties, if one exists. In some cases, referral to a
debt recovery unit may also be necessary.
The subscriber should explore a range of options with the customer. Usually this will require the customer to disclose to
the subscriber details of their income, expenditure, assets and liabilities, including amounts (if any) owed to other
creditors. This information will be used to develop a plan for dealing with the liabilities. In cases where there are liabilities
to multiple creditors, subscribers should recommend a free money advice service (see section 14.4).
The initial arrangements for repaying the debt should be in writing or other durable medium. This will not always be
treated as a formal debt management plan, and there may be departures from this plan, if it is in the interests of
subscribers and customers. There is no need for every small departure from the basic plan to be in writing (for example
an agreement to accept a lower repayment for one week), but any amendments that change the fundamental nature of
the plan should be in writing. If, at the subscriber’s discretion, the plan includes an agreement to accept smaller
repayments, the subscriber should tell the customer whether this is regarded as ‘falling behind with repayments’ and
whether information will be passed to Credit Reference Agencies.
If the customer does not co-operate with the subscriber, a plan cannot be developed and the subscriber may proceed
with normal debt recovery procedures. Lack of co-operation would include not responding to the subscriber’s attempts
at contact and unreasonable demands by the customer (for example, a request that the debt be written off or repaid
over a very long period, even though the customer could afford to make reasonable repayments).
The subscriber should take into account any other accounts that the customer may have with the subscriber if these
have a credit balance. In addition, if a customer has assets which could reasonably be expected to be sold to reduce
outstanding debts, the subscriber may request that the customer, and if appropriate, their adviser, considers this option.
Thereafter, the subscriber should acknowledge that income should only be used to repay ‘non-priority’ debts once
provision has been made for any ‘priority’ debts. The subscriber should leave the customer with sufficient money for
reasonable day-to-day expenses, taking into account individual circumstances. Subscribers will not subject customers to
harassment or undue pressure when discussing their problems.
A debt is considered ‘priority’ where the customer’s failure to pay could lead directly to the loss of one or more of the following:
• the customer’s home (e.g. rent, mortgage, secured loans);
• their liberty (e.g. council tax, child support maintenance, income tax, court fines);
• their utility supplies (e.g. water, gas, electricity); or
• their essential goods or services (e.g. a cooker, a fridge, or the means to travel to work).
Subscribers should consider appropriate concessions, relating to charges and interest payable by the customer, where
the customer is constructively cooperating with the subscriber. Considerations might include reducing or suspending
interest, charges and fees where agreed repayments do not cover them. The nature of any concessions will need to be
assessed on a case-by-case basis, taking account of the seriousness of the customer’s situation. (Charges will have
been communicated to the customer under section 5 of the Banking Code.)
Token offers may be accepted where the customer has demonstrated they have no surplus income available for their
‘non-priority’ creditors and there is a realistic prospect of the customer's circumstances improving. A token offer will not
necessarily be sufficient to prevent the subscriber from selling the debt to a third party debt recovery agent and to
prevent the debt from being registered as a default with the credit reference agencies.
Where the subscriber considers the customer’s personal and financial circumstances to be exceptional and unlikely to
improve, the subscriber may, among other options, consider writing off or not pursuing part or all of the customer’s
debt(s). Where write-off is requested by a customer or adviser but is not considered appropriate by the subscriber, the
subscriber must give their reasons in writing. If the subscriber agrees to a write-off, then the debt may be registered as a
default with the credit reference agencies.
Repayment plans between subscribers and customers may be subject to regular review. Any review period will be
agreed with the customer or their adviser, and subscribers should seek to revise contributions only at the end of the
review period or if a customer’s personal circumstances change. (Customers and/or their advisers should inform the
subscriber if the customer’s personal situation changes.)
14.4 If you are having difficulties, you can also get help and advice from debt-counselling organisations.
We will tell you where you can get free money advice. If you ask us to, we will work with debtcounselling
organisations, such as Citizens Advice, money advice centres or the Consumer Credit
Counselling Service. Their contact details are as follows.
• Advice UK – 020 7407 4070 (adviceUK : Advice UK Homepage)
• Citizens Advice bureaux – You can get the phone number of your local bureau from the phone
book, the local library or www citizensadvice.org.uk
• Citizens Advice Scotland – 0131 550 1000 (The website of the Citizens Advice Bureau Service in Scotland
)
• Consumer Credit Counselling Service – 0800 138 1111 (CCCS - Free Debt Advice from the UK's Leading Debt Charity
)
• Money Advice Scotland – 0141 572 0237(Money Advice Scotland Online)
• National Debtline – 0808 808 4000 (National Debtline, for FREE CONFIDENTIAL and INDEPENDENT ADVICE call 0808 808 4000)
• Payplan – 0800 917 7823 (Free Debt Management company | Debt Advice | Payplan)
You should also be aware that there are other companies that charge a fee for managing your debts.
It is your responsibility to check the fees that may be charged before asking these companies to act
on your behalf.
This paragraph formally acknowledges the role of money advisers. Subscribers should tell customers where they can get
free money advice when the subscriber thinks the customer is in financial difficulties. Subscribers may give customers
time to consult a money adviser (this would not prevent subscribers protecting their position if necessary), and will be
prepared to enter dialogue with a money adviser when an appropriately completed authority to disclose information has
been received, either by fax or post (original or photocopy).
Subscribers will also work with a nominated adviser from an organisation not listed in section 14 of the Code, unless
they have reasonable grounds for believing that it would not be in the customer’s interests.
Communications with customers and/or their advisers should, wherever possible, acknowledge and reflect any previous
discussions that have taken place. Subscribers should be willing to communicate with customers and/or their advisers
by phone, post or fax. Normally, the subscriber will communicate through the adviser, if an authority has been received.
This does not preclude subscribers from copying correspondence to customers if they choose. In certain circumstances
it may be beneficial for discussions (either face-to-face or over the telephone) between the adviser and subscriber to
take place with the customer present.
On occasions the subscriber may need to contact the customer directly, even when an authority is in place. These
occasions may be the result of the adviser not being available, failing to provide requested information within a
reasonable period of time, or other similar circumstances.
Subscribers should give a phone number on all communications that will put the customer in contact with a named
person or a team dedicated to dealing with cases of financial difficulty.
14.5 If you have debts with many creditors, a debt-counselling organisation may complete a Common
Financial Statement (or an equivalent statement we accept) on your behalf, which we will accept as
the basis for negotiations with you in drawing up a debt-management plan.
This provision is designed to help people in financial difficulties, and some subscribers may only apply it when accounts
have gone into default. Other subscribers may choose to use the provision at an earlier stage if it benefits both them and
the customer.
Money advisers will use the BBA/MAT/FLA Common Financial Statement format and principles when submitting
information to subscribers5.
Subscribers should accept the Common Financial Statement (CFS) (and other similar statements such as that used by
the Consumer Credit Counselling Service (CCCS)). The CFS – or equivalent details of the customer’s income,
expenditure and assets – is necessary to enable the subscriber to gather information to assess if an ‘offer to pay’ will
enable the customer to be accepted onto a formal debt management plan (DMP), or enable the subscriber to reduce or
suppress interest and fees.
The third party money adviser should ensure that their authority to act on behalf of the customer is promptly sent to all
creditors identified by the customer. It is also the responsibility of the adviser to ensure that a CFS or equivalent is sent
to the creditors shortly after the authority. In these circumstances, where a money adviser has been appointed and there
are debts with many creditors subscribers will not normally be able to work with the customer until a CFS or equivalent
has been received.
In general, subscribers should then be prepared to accept an offer of repayment which is based on the principle of
equitable distribution of available income (after priority payments), in line with the amount outstanding to each creditor.
Alternative means of calculating the distribution of available income by the customer or their adviser may be agreed on a
case-by-case basis. A subscriber may accept an offer of payment, even though the offer is not sufficient to enable the
customer to be accepted onto a formal DMP.
14.6 In certain circumstances we may pass your debt to another organisation or debt-collection agency. When
arranging how you will make your repayments, we will always choose reputable firms which agree to follow
the Code.
Subscribers should follow a due diligence process when selecting third parties for debt management, which should
include third party compliance with Data Protection legislation, Consumer Credit legislation, Office of Fair Trading
guidance on debt collection and debt management, and the code of the Credit Services Association.
Subscribers should use all reasonable endeavours to ensure that the Code standards for handling financial difficulties
contained in section 14.1 of the Code are applied by such agents. Code compliance standards should form part of all
third party contracts agreed on or after 31st March 2002. Subscribers should pass on relevant information to enable the
third party debt manager to recover the debt.
14.7 In other circumstances we may sell your debt. We will always choose reputable firms if we do this.
Subscribers should follow a due diligence process when selecting any third party for debt sale. Any new contract
entered into after March 2005 with such companies should ensure that the third party will comply with Data Protection
legislation, Consumer Credit legislation, Office of Fair Trading guidance on debt collection and debt management, the
code of the Credit Services Association and the Banking Code’s standards for handling financial difficulties contained in
paragraph 14.1 even if the debt purchaser is not a subscriber. The subscriber will inform the third party of any relevant
arrangements currently being complied with by the customer.
It is common practice for third parties taking on a debt to request a new statement of income, expenditure and assets to
understand the customer’s most up-to-date position.
