banks formal views on the CCA - response to BIS

[Amethyst]

Obtained under the Freedom of Information Act from BIS by enaid, this is most definately worth a read Legal Beagles Consumer Forum - View Single Post - Barclays - BIS consumer credit response

[Garlok]

Re: Barclays formal views on the CCA - response to BIS

Says it all about Barclays.

regards
Garlok

[Amethyst]

Re: banks formal views on the CCA - response to BIS

lloyds, hsbc and rbs coming soon as I can get them uploaded xx

[EXC]

Re: banks formal views on the CCA - response to BIS

This is interesting.

[Garlok]

Re: banks formal views on the CCA - response to BIS

However all is not lost at the moment. It would take a while for these changes to brought in PLUS under the terms of the Lisbon Treaty, and the bits of the protections for consumers our wonderful leaders were unable to wriggle out of:--

As a European citizen , and my passport says I am without my consent, I cannot be disadvantged by any retrospective laws brought in by a member nation!!!

AND the European court judges are pretty miffed with British courts at the moemnt.

regards
Garlok

[Amethyst]

Re: banks formal views on the CCA - response to BIS

Banks and OFT responses to BIS consultation - Legal Beagles Consumer Forum

Lloyds, HSBC and RBS responses are here
http://www.legalbeagles.info/FOI/FOIRBS1.pdf - RBS
http://www.legalbeagles.info/FOI/FOIHSBC1.pdf - HSBC
http://www.legalbeagles.info/FOI/FOI...nkingGroup.pdf - Lloyds

[Amethyst]

Re: banks formal views on the CCA - response to BIS

The OFT reports are available on that same link too but the CCA section is very heavily redacted.

[jebedee]

Re: banks formal views on the CCA - response to BIS

Thats all fine and dandy BUT you should look at the the new approach to financial regulation consultation on reforming the consumer credit regime on the BIS website. Page 15 if you are short of time. Oh, and option 1 is the preferred option apparently.

[Amethyst]

Re: banks formal views on the CCA - response to BIS

http://www.hm-treasury.gov.uk/d/cons...edit211210.pdf

Option 1: a regulatory regime for consumer credit under the CPMA within a legal framework based on the model set out in the Financial Services and Markets Act 2000 (FSMA) and therefore consistent with the regulation of other retail financial services; or
1 New legislation introduced to enable Quango reforms | Cabinet Office


Option 2: a specific consumer credit regime based on the Consumer Credit Act 1974 (CCA).


Impact of option 1

Other key non-monetised benefits by ‘main affected groups’
Avoidance of costs incurred by business and consumers from improved oversight (e.g. potential reduction in problem debt/write-offs, reduced detriment associated with problems flowing from slow legislative response);

lol.

[jebedee]

Re: banks formal views on the CCA - response to BIS

I would point out the bit that says "the CCA would be repealed and consumer credit regulation would be moved to sit within the same regime as other retail financial services." Which begs the question if option is the preferred option and the CCA is repealed, then why are the other consultations seeking comment on the provisions of the CCA? Which is highlighted in the banks responses to the consultations listed early in these posts. Makes you think doesn't it?

[Amethyst]

Re: banks formal views on the CCA - response to BIS

Well I think some further FOI's will be going in shortly (comms between BIS and HMT/MOJ ?? ) They must have communicated with Europe or something about the consumer credit directive too.... and of course for the responses at the end of March...what do you reckon jebedee ?

[jebedee]

Re: banks formal views on the CCA - response to BIS

It is still an open consultation, so feel free to answer the consultation. The CCD will be "protected" but perhaps not in the CCA, maybe in one the myriad expected rulebooks that might result from this. The protections of the CCA may well disappear, but not all of the CCA has kept pace with society or the lending industry. BUT we may be throwing the baby out with the bathwater. Try to think which bits you would wish to retain (in whatever form) and I now refer to my first sentence.