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  • Archive of blogs to June 2015 Posted on 23 June 2015

    Fairer finance for low-income families

    The Centre for Social Justice’s (CSJ) new report, Future Finance, makes a powerful case for a new approach to tailoring financial services to the needs of low-income families. The report looks beyond the new regulation of payday and other high-cost lenders that have contributed to an estimated nine million people in the UK struggling with over-indebtedness and over 2.5 million children living in families with problem debt. It focuses instead on how ‘Alternative Financial Institutions’ (AFIs, including social enterprises credit unions, community development finance institutions but also potentially for-profit firms) could employ innovative financial technologies to offer affordable financial products and services that allow people to maintain or regain control of their own financial situations.

    The CSJ argues that for too long issues with problem debt amongst low-income households have been addressed in silos (financial inclusion, financial education, financial capability, affordability, etc.) whereas tackling problem debt requires a “new positive vision and a holistic approach centred around meeting the wants, needs and choice of people and families”. Solutions could include current accounts that are basic but not simplistic, offered by a range of AFIs but supported by a common technology infrastructure. These accounts should be easy to open and simple to operate, but (using new technology) could provide advanced budget planning tools such as forecasting of future bills and expenditures based on past activity. They could also support lending based on far more sophisticated credit assessment than is typically available today for typically ‘thin file’ low-income households (apparently the credit agencies have very limited data on nearly 30% of the UK adult population).

    The CSJ proposes a new independent body, the Alternative Finance Foundation, to facilitate the growth of a competitive market for AFIs. In light of the huge resources now being applied to the regulation of payday and other parts of the consumer credit market, it makes sense for there to be a parallel investment in developing financial services that better meet the needs of low-income families.

    Posted @ 19:46:43 on 07 June 2015
     

    Peer to Peer goes institutional

    AltFi.com, the electronic newsletter for the “alternative” finance sector, reported yesterday on the tie-up between Metro Bank and Zopa, apparently the first time a UK bank has channelled funds directly into a peer-to-peer platform (rather than referring businesses to a platform).

    That news came on the same day as the website published statistics showing that around 30% of Peer to Peer lending is now institutionally funded, up from zero just over a year ago. There’s even a debate over whether Peer to Peer is still an appropriate name for the sector, given the growing role of the institutions.

    Fund managers buying into Peer to Peer include Axa Framlington, Woodford Investment Management and F&C Investment. So what is driving fund managers’ interest? Earlier this month AltFi.com quoted George Luckraft of Axa Framlington: “It is a young industry and there will naturally be concerns. However, some of these platforms have access to better information than banks do.”

    The Government’s British Business Bank surely (BBB) deserves credit for encouraging the investors through its own stakes in P2P lender Funding Circle, and the BBB is working hard to achieve the same in asset finance.

    We have seen some investor activity in the asset finance sector, with recent acquisitions of a handful of brokers for example. However there remains a dearth of institutional investment directly into deals, whether through lending platforms, sale of asset-backed securities or full-blown securitisations. This despite the fact that asset finance lenders almost certainly have some of the best information on their clients in the business finance sector.

    This blog has noted before the need for industry-wide data on probability of default and loss given default. Without this it is very difficult for fund managers to obtain approval from their credit committees for potential investments. The P2P sector not only collects but publishes this data in spades through the Liberum AltFi Returns Index. It is also remarkably well-organised and the firms are investing together to promote their sector to the investor community.

    We may have our doubts about the long-term viability of P2P lending but take a look at AltFi.com and it’s difficult to conclude that there aren’t things we can learn from this still-nascent sector.

    Posted @ 16:42:41 on 20 May 2015
     

    Regional banks: A Labour manifesto commitment that deserves to be kept alive

    Had the Labour party been elected it planned to establish regional banks. The idea was to create networks of lenders in every region based on the Sparkassen model in Germany. The banks would have a civic duty to promote local growth and only lend to firms operating in their area.

    Few could argue against the concept that smaller regional banks with local managers who know businesses in their area well would benefit SMEs. Even George Osborne has suggested that banks go back in time to the ‘Captain Mainwaring’ style of local bank manager who knows the local businesses. Making this viable without huge Government intervention is the problem.

    Fortunately there are at least two components of a solution within reach.

    First is the network of commercial finance brokers in each region. Taking the West Midlands as an example there are at least 50 asset finance brokers spread out across the region (listed on our Asset Finance 500 website) and probably another 50 brokers specialising in invoice finance, commercial mortgages and other business loans. It could be a major step forwards in raising awareness of the support they can provide if they were to jointly explain their services to the 350,000 SMEs in the region. Most are not members of any trade association but they could perhaps meet together under the auspices of local university business schools or councils.

    Second is the support available through the European Investment Bank and the European Investment Fund for schemes to help SMEs obtain finance. There is a huge disparity between the amounts of very low-cost funding available for SMEs in the UK from the EIB and that in most other European countries. The EIB seems keen to address this but it needs proposals to be made from highly credit-rated counterparties, whether they are banks, non-bank finance institutions, universities, large companies or other institutions.

    What’s needed now is to pull the pieces together - the network of brokers, the EIB/EIF and the banks or other institutions that could sit in the middle. Perhaps that coordinating role is what Labour might have delivered. However it shouldn’t need a change of Government to achieve this.  Regional banks might best be achieved through collaboration at regional level rather than waiting for anything to happen in Westminster.

    Posted @ 17:21:53 on 11 May 2015
     

    Should we care about the audit threshold change?

    From 6 April, companies with turnover of up to £10.3 million will no longer have to file complete and audited accounts at Companies House, following the Government’s decision to implement in full the EU Accounting Directive.  Previously, the threshold was £6.5 million turnover.

    This is the latest in a series of increases in the audit threshold over the last decade. It’s also the largest increase in absolute terms although not if measured by number of businesses affected.

    As lenders, it makes the information on which lending decisions are based less reliable. The credit agencies won’t shout about this, but their ability to provide reliable credit reports on businesses that file abbreviated and unaudited accounts at Companies House is limited. Lenders themselves can ask companies for full and audited accounts, but this risks alienating the customer, adds cost and causes delays.

    The cumulative effects of the audit threshold rises means that smaller accountancy practices have to reinvent themselves to survive. The best are seeing this as an opportunity to get more involved in helping their clients manage their financial affairs, rather than just reporting on how they have done after the event. This is extending in some cases to offering help sourcing new finance.

    It’s difficult to argue against deregulation, particularly when it happens in small steps over a long period. However it seems far from ideal that we are left now with only the top one per cent of UK businesses having to file full and audited accounts.

    Posted @ 09:19:26 on 29 April 2015 
     

    Why the FCA is affecting a lot more than consumer credit

    As this blog has pointed out before, regulated consumer credit business is a very small part of the asset finance market, probably representing no more than 2% of total business by value. However the impact of the FCA’s regulation of firms stretches far wider and the real effects are just beginning to become clearer.

    As noted on the Regulatory Updates page of our website, the FCA has recently proposed banning charging clients for ‘optional additional products’ unless the client has specifically agreed to pay for the product. The implications for the sale of insurance or maintenance-type arrangements for leased equipment are still unclear, but it seems likely that FCA-authorised firms will need to review whether they can promote schemes where insurance or similar products are charged for automatically unless the customer demonstrates they already have cover. If that proves to be the case, it could make it harder for lessors to ensure equipment is insured, potentially increasing risk and the cost of lending.

    In a consultation ending in May, the FCA is also seeking views on how brokers receive commissions. It notes the different ways commission can work, including where the broker has the discretion to set the rate for individual customers. The FCA is seeking views on the advantages and disadvantages for firms and for consumers of the different commission arrangements. This seems to be an exercise in finding a problem that doesn’t exist. However he regulator will be concerned that customers might not understand how the commission is built into the rate, as economic theory would suggest this could restrict competition. Further change in this area does seem likely although it may well be something the FCA is happy to deal with over the medium to long term.

    There’s certainly more to come. The more we can do to predict where the FCA’s concerns are likely to be and address them, the less the risk of heavy-handed remedies that make it harder for customers - regulated or not - to use asset finance.

    Posted @ 15:37:53 on 09 April 2015
     

    What will have the biggest impact on SME Finance - challenger banks, alternative finance, or the competition regulator?

    The House of Commons Treasury Committee’s report into Conduct and competition in SME lending, published last week, covered a lot of ground. Its conclusions on the RBS Global Restructuring Group, and on the FCA’s interest rate hedging product review, have been widely reported. However it is the Committee’s analysis of competition in SME lending, and of the state of the alternative finance sector that may be of most relevance to asset finance.

    In the week that Aldermore floated and Shawbrook confirmed its plan to list on the stock market in April, the Committee sounded a cautionary note on the role of the challenger banks as well as providers of ‘alternative’ finance (crowdfunding / peer-to-peer). The SME banking market share of banks outside the top 5 largest is less than 5% and the peer-to-peer sector represents only around 1% of new SME lending. “Challenger banks and alternative lenders are therefore not yet at a scale sufficient to challenge incumbents” the Committee concluded.

    The Committee came close to calling for a break-up of the large banks. ‘Behavioural’ remedies (such as data sharing and faster account transfers) have not addressed the competition problem in SME banking, the Committee concludes, so ‘structural’ reforms may be “essential to secure a reduction in concentration in the market”. The Competition and Markets Authority’s (CMA) ongoing inquiry into SME finance should include a “detailed examination” of whether ‘structural’ remedies (such as forced break-ups) are needed, the Committee recommends.

    One structural option that the CMA is likely to consider is to require the large banks to separate their business current account and business lending activities. As noted in our regulatory update on the CMA’s inquiry last November, the CMA is considering the possible anti-competitive effects of linkages between business current account and lending products.

    The implications for asset finance are unclear. So far the CMA has seemed fairly oblivious to the importance of leasing. The CMA’s draft market study on how SMEs apply for loans didn’t even recognise the existence of finance brokers (AFP has pointed this out to the CMA). What is becoming clearer is that the CMA inquiry - which has another year to run - could end up having a bigger impact on the SME lending market than the rise of challenger banks and alternative finance.

    The CMA has the legal duty and powers to take whatever steps are necessary to remedy the competition problems that it identifies, independent of who is in Government. Increasingly this inquiry is looking like it will lead to decisive action.

    Posted @ 15:49:49 on 15 March 2015
     

    Being the ‘good guys’ with HMRC

    At the FLA dinner on 24 February, Guest speaker Robert Peston, BBC News economic editor said: “I feel passionately that you lot are the good guys, and what you do is absolutely vital for our economy”.

    It was a brave statement given the diversity of his audience but certainly one that properly reflects the role of the leasing industry. How things have changed from less than ten years ago when every year at Budget time, and often in-between too, the Chancellor would announce changes to legislation to close down what were described as leasing tax avoidance schemes.

    In reality these had little to do with genuine leasing. They were often schemes designed to exploit weaknesses in the leasing tax rules, making arrangements look like leasing when actually they weren’t. They harmed the reputation of our industry and made it more difficult for leasing companies to finance real business investment. The scale of some of the leasing schemes and the potential threat to the Exchequer was, I was reliably informed, quite staggering.

    The problem has not completely gone away. Last week HMRC issued new rules preventing firms from claiming capital allowances on items of plant and machinery they have acquired if they haven’t paid an open market price for them. HMRC said this was in response to proposed sale and leaseback arrangements that could have created substantial capital allowances on assets that had previously entitled their owners to no allowances.

    The effectiveness of this Government’s new anti-avoidance measures, together with recent damaging reports into the tax avoidance activities of large audit firms, mean that steps like the one last week are fortunately now few and far between. With tax avoidance fast becoming an election issue, the Liberal Democrats are proposing making failure to prevent tax evasion a criminal offence, targeting accountants, lawyers and bankers. That seems a particularly impractical policy. However it’s still lucky that those involved in the real leasing industry - lessors and advisers alike - are now firmly recognised as the ‘good guys’.

    Posted @ 19:14:55 on 27 February 2015
     

    Finding better solutions for consumer equipment finance

    Today’s report from the All Party Parliamentary Group on Debt and Personal Finance (APPG Debt) of its Inquiry into the Rent to Own (RTO) sector makes for uncomfortable reading. It’s no surprise that stores such as BrightHouse charge interest rates approaching 100% for rental of electrical goods. The main issue however seems to be the way insurance and services are bundled with the equipment costs, greatly increasing the amount being financed. An FCA review of how insurance and service for financed equipment is sold now seems likely.  

    This comes at a time of growing interest in the ‘sharing economy’ when equipment finance solutions for consumers should really be coming into their own. The solution could rest less with high street retailers such as BrightHouse and more with vendor finance schemes, where manufacturers are willing to support more flexible and better value rental arrangements run by specialist finance companies. A strong case for “the ultimate vendor leasing company” is made by Pascal Feijt of ING Lease Netherlands in the latest report of Leaseurope’s Future Group which is just published (www.leaseurope.org).

    Posted @ 15:44:50 on 10 February 2015
     

    Making the case for equipment investment in the NHS

    Parliament’s Public Accounts Committee’s new report published 3 February, Financial Sustainability of NHS Bodies, identifies the need for increased investment as a way of alleviating financial pressures on the NHS.

    The report notes that both NHS England and sector regulator Monitor agreed that upfront investment was needed to achieve system efficiencies by changing the way healthcare is provided. However with a growing number of organisations in deficit, the money for this was limited.  The Committee recommends that the Department of Health should accelerate the disposal of surplus capital assets to release cash for upfront investment in new models of care.

    The notes of the Committee’s hearings provide some valuable further insights. Richard Douglas, Director General of Finance and NHS, Department of Health, told the Committee the Department would be looking again at the capital regime that operates in the NHS. “We currently have a capital regime that basically allows people to borrow against their income; there is no strategic ownership of capital planning. We need to change that in order to release some of the resource for investment” he said, noting that the NHS invests a lot more in bricks and mortar than most [other healthcare providers] and a lot less in equipment and IT.

    Such a recognition of the importance of investment in new equipment - as an integral part of the renewal of entire care solutions - will be music to the ears of the small but dedicated group of UK leasing professionals specialising in serving hospital trusts. Once the case for new equipment investment is clear, it should be a lot easier to demonstrate the value of leasing and to overcome the bureaucracy that currently surrounds its use in the NHS.

    Posted @ 18:09:59 on 03 February 2015
     

    Is another review of railway operating stock leasing heading down the line?

    As reported on the Policy Issues page of this website, the Office of Rail Regulation (ORR) issued a consultation on 18 December on the effectiveness of the legal Order put in place following the Competition Commissions’ (CC) 2009 investigation into the train operating stock leasing market. On one level, this is a routine five-year review of a fairly unimportant outcome of the CC’s investigation. However the ORR has thrown in a question of whether any important changes have taken place since the Order came into force in February 2010.

    The CC’s investigation had concluded that there were problems in the rolling stock leasing market which were having an adverse effect on competition. The Railway Operating Stock Companies (ROSCOs) in many cases had weakened incentives to compete on lease rentals, the CC said, and costs faced by Train Operating Companies (and hence taxpayers and passengers) could be higher than they should be. However the remedies put in place by the CC to address these issues fell short of what the Government wanted. In a forthright response, the Government noted that the CC’s panel had been unable to reach a consensus on the need for a price control on the three ROSCOs. The Government said it would closely monitor the rentals proposed when rolling stock is re-leased.

    The ORR’s consultation was issued a fortnight before the latest regulated train fare price increases of 2.5%. With around 11p of the passenger’s pound being spent on leasing stock, it seems likely that the next Government will want to take the opportunity to review whether the CC’s unusually light-touch remedies for this market have been proven to be the right solution. Although this part of the leasing market is in many ways a unique global showcase of the benefits of leasing to transportation operators, it does seem likely that the ORR’s consultation will lead to a more fundamental review than its low key pre-Christmas announcement might suggest.

    Posted @ 18:31:49 on 04 January 2015
     

    Time for Department for Business to act on FCA small business finance regulation

    As reported in our policy update (see page 5 of the website) yesterday the FCA announced new rules on how brokers deal with their customers. They are doing so without prior consultation on the basis that any delay could harm consumers. It's all very well and it's easy to see why the FCA feels a need to act quickly to deal with issues affecting individual consumers. However it's getting beyond a joke that the FCA can still issue statements on the consumer credit market that take no account whatsoever of the impacts on small businesses that are caught by this regulation. Around 2 million SMEs are covered by the consumer credit rules, for no obvious reason. Each time the FCA imposes extra regulatory burdens on business finance brokers - most of which are small businesses themselves and ill-equipped to cope with more red tape - competition and choice in the market is reduced a little. The Department for Business appears to have done nothing so far to hold the FCA to account on this issue. The least it could do is insist the FCA apply the same small business impact tests to new regulation as are required for central Government departments. 

    Posted @ 14:18:33 on 02 December 2014
     

    Why FCA consumer credit regulation could get a lot worse for asset finance - unless we do something about it

    As the first asset finance brokers receive their consumer credit authorisations from the Financial Conduct Authority (FCA) we might conclude that the FCA challenge for our industry is under control. Unfortunately, the effects of the new regulation are about to get a lot worse, unless we find ways of working together to deal with the problem.

    The majority of asset finance brokers in the UK - of which there are over 500 listed on www.assetfinance500.uk - have started or are about to start completing their FCA application packs. Most ‘landing slots’ (application periods) for brokers end over the next six months.

    Many brokers have attended briefings and are being offered free support from FCA compliancy specialist consultants to get themselves FCA authorised. Done properly, preparing an FCA application takes around 2 to 3 days for a small broking firm. That’s 2 to 3 days less time helping businesses to get the finance they need. On the positive side, it could help to protect the reputation of the industry by keeping fly-by-nights out.

    Early indications are that the FCA are taking a relaxed line with asset finance industry applicants, perhaps asking a question or two but not being too pernickety, provided the application pack is completed accurately and properly describing the broker’s business.

    Even with the help, the application process is still difficult for smaller firms in particular. Some are deciding to merge their businesses, which is a big step but brings various potential advantages. Apart from sharing the regulatory burdens there could be tax benefits and better bargaining power with funders. It may be possible for the individual brokers to keep their own customers and even trading names.

    However many brokers are asking why this is all necessary when such a small proportion of their business - often well below 10% - comes from regulated customers.  If the broker is willing to restrict itself to dealing with companies and larger partnerships, it doesn’t need to be authorised by the FCA at all. So is dealing with all the extra regulation worth the trouble?

    Latest Companies House figures show that more and more small businesses are incorporating. There are now over 3.3 million companies in the UK. Over 500,000 new companies are started each year, compared to around 330,000 dissolutions, so the stock of companies is growing. Over two-thirds of small businesses are already incorporated. Those which are unincorporated tend to be very small and therefore far less likely to need equipment finance. The total value of regulated agreements is probably no more than 5% of the UK business asset finance market.

    For such a small part of the industry and in light of so much regulation, why don’t brokers just rule out dealing with regulated customers? The majority of lessors in the UK already do exactly that. There seem to be two main reasons. The first is that some customers that do have strong equipment finance needs are small partnerships (which are regulated) particularly in the farming industry. The second is that some funders working with brokers (but certainly not all) are still insisting that all their brokers are FCA authorised, whether they need it or not.

    If the FCA regime is problematic for brokers, what about the equipment dealers (for dealers also read vendors, resellers, distributors, agents, etc.) who offer finance to their customers? There are probably over 5,000 such firms across the UK. The majority - mostly smaller firms - introduce customers to brokers, often for no commission. The minority - mostly larger firms - introduce direct to finance companies. Most have later landing slots in the second half of 2015, so may not yet appreciate the scale of the regulatory burden that is about to hit them.

    It’s bad enough for a broker to have to take several days out of his or her business to prepare their FCA application, but at least they are in the finance business. For an equipment dealer to do this seems a much bigger deal, for what is only a secondary part of its business.

    It’s worth addressing two common myths here. First, the FCA’s “limited permission” regime that applies to many vendors is not very different from the “full permission” regime that applies to brokers. Perhaps it removes half a day from the preparation work, but that’s about it. Second, there’s very little scope for arguing that any referral of an unincorporated business or small partnership from a vendor to a broker or funder is somehow unregulated. This argument will rarely work.

    As we get closer to the crunch period when large numbers of equipment dealers have to apply for FCA authorisation, the industry needs to find ways of supporting them.

    The simplest approach is for funders to accept that some intermediaries are not dealing with regulated customers (or are happy to stop doing so) and therefore shouldn’t have to apply for FCA authorisation. Strict procedures would be needed to ensure that no regulated customers are then dealt with, which could be problematic for dealers. For example, promotional material and agreements would specify that finance is available for only large partnerships or companies.

    For larger dealers who are handling regulated customers and are able to cope with the new regulation, finance companies could offer support with the authorisation process working with compliance specialist consultants as they have for brokers.

    That still leaves large numbers of smaller dealers who handle at least some regulated customers. A potentially useful approach could be to allow them to be Introducer Appointed Representatives (IARs) of other firms that do have FCA authorisation.  The dealer isn’t then FCA authorised. Instead another authorised firm takes responsibility for the relevant activities of its IARs.

    As the dealer’s activities are restricted to just introductions (i.e. just passing on contact details) it shouldn’t be too onerous in theory, although it is still a serious regulatory and legal commitment for the Principal (the FCA jargon for the firm taking responsibility for IARs).  It might involve, for example, asking customers who have been introduced whether the equipment dealer told them about the different types of asset finance. In the slightly bizarre regulated world, the answer to that question should actually be no. That’s because all the IAR is allowed to do is to refer customers to the other firm, i.e. the broker or finance company. It’s then for the regulated firm to discuss the products and all other details.

    So far it seems very few brokers or funders are planning to become Principals. For any single broker or funder it seems a lot of extra work for a small amount of business. For the vendor finance industry as a whole, however, it seems vital to the future of the channel that this option is provided.

    It should be feasible for a specialist firm to act as a Principal. They could appoint and supervise many dealer IARs. The dealers would then introduce their customers to that firm, and that firm (with its FCA authorisation) would then introduce the same business through to one or more brokers or funders. The Principal would charge for its services, both operating a referral system (probably online) and carrying out appropriate checks and inspections.

    Setting up such a specialist firm wouldn’t be straightforward. It would require systems expertise, a sound knowledge of the industry, experience in FCA compliance management, and time to obtain FCA authorisation. No single firm is likely to have all those skills so an alliance of different experts with the support of the industry is likely to be needed.

    These solutions - funders agreeing to deal with non-FCA authorised introducers for non-regulated business, offering specialist support for dealers who do proceed with FCA authorisation, and ensuring that smaller dealers can make simple introductions as IARs without needing to be FCA authorised - need the industry’s collective attention. Otherwise there’s a real danger that the FCA regulatory burden - for what is only a very small part of the industry - could spin out of control.

    Posted @ 16:33:02 on 03 November 2014
     

    Last Chance Saloon isn’t a good place to be

    It seems that RBS is following Santander down the route of referring businesses that it rejects for loans to the Peer to Peer (P2P) lenders. The Financial Times today calls it a "last chance saloon" for the rejected businesses.

    It follows an ongoing Government initiative through the Small Business, Enterprise and Employment Bill winding its way through Parliament that will force banks to refer rejected businesses to so-called ‘lending platforms’ that will, miraculously it seems, find finance where the bank couldn’t.

    This raises all sorts of issues, including whether the banks are restricting their lending to businesses holding current accounts with them (which, as HSBC and First Trust Bank were reminded by the Competition and Markets Authority earlier this week, is not permitted under competition rules); whether the P2P sector is carrying out robust due diligence on loan applications; and why Government believes the way to improve bank lending decisions is to force banks to pass their problem cases on to others.

    What’s needed is a way of helping businesses to avoid getting anywhere near the Last Chance Saloon of business finance. Commercial finance brokers are ideally positioned to help, matching businesses’ needs to an ever-widening range of sources of finance. Unfortunately too few businesses are aware of brokers or how to find them. They assume the only finance provider in town is their bank.

    Part of the reason is that until recently directories of brokers have been very limited, none covering more than 1 in 10 brokers. Asset Finance Policy’s new free directory, www.assetfinance500.uk already lists more than 500 brokers specialising in asset finance, and it could be expanded to cover all types of brokers. The answer to bank lending problems is not to send rejected applicants to a P2P Last Chance Saloon. It’s to persuade businesses that their local commercial finance broker is their First Chance Saloon.

    Posted @ 16:26:24 on 25 October 2014
     

    EC breakthroughs on leasing liquidity and securitisations

    Last Friday as industry leaders met at the Leaseurope Convention in Barcelona, the European Commission adopted new rules that will be important and beneficial to the leasing industry.

    The new detailed rules for the liquidity coverage requirements for banks confirmed that specialised credit institutions engaged in leasing and factoring would be exempt from the cap on inflows that applies to other bank loans. Hence banks can assume that income from leases will be received when expected whereas for other loans caps on inflows apply. The EC says that this preferential treatment reflect the low liquidity risk and importance to the real economy of leasing (for automotive and consumer leasing a 90% cap on inflows is applied).

    Meanwhile the new detailed rules to implement the Solvency II directive for insurers will make it easier for insurers to invest in the asset finance market through securitisation-type arrangements, relaxing the amount of capital insurers must hold when making such investments. The EC says this will incentivise insurers, acting as investors, to channel more funds into safe, simple and transparent securitisation markets in Europe, contributing to their development and liquidity.

    Neither announcement will change the market overnight. However both are significant in recognising the importance of leasing and creating the conditions needed for a more diverse market. They follow the completion of Leaseurope’s Basel 3 research programme that - for the first time - provided extensive pan-European data on the risk profile of leasing, demonstrating beyond reasonable doubt the value of such cross-industry performance data.

    Posted @ 15:44:56 on 12 October 2014
     

    Why asset finance is not growing

    In an interview with Asset Finance International reported last week, Investec’s head of asset finance Mike Francis, expressed his concern that the UK asset finance industry is failing to raise its profile and extend its reach. “The industry is not growing and has rested at the £20 - £25 billion per annum penetration level, representing around 30% of fixed capital investment excluding property, for several years now”, Mike said in the interview.

    There are some grounds for taking a more optimistic line. First, the UK asset finance industry has one of the highest penetration levels of business investment in Europe (the average across Europe being around 20%). Second, the FLA issues monthly press releases consistently report a growing market (July’s new business up 23% on the previous year and reported as ‘buoyant’ and the first half of the year was up 10%). Third, awareness of asset finance amongst businesses seems quite healthy and is increasing (the latest BDRC SME Finance Monitor reported that 31% of businesses seeking or renewing finance would consider leasing, up from 23% two years ago, and of course many businesses seeking finance don’t need it for equipment).  

    These statistics may provide some grounds for optimism, but perhaps they also confirm the problem. Despite the relatively strong penetration levels and encouraging new business and awareness statistics, longer term growth is missing. The FLA reported total volume of £22.4 billion in 2013. In 2003, new business was £25.8 (roughly £35 billion today). In 1993, new business was £13 billion (£23 billion today).

    Perhaps the lack of growth is inevitable, an outcome of the changes to tax rules and of the much lower cost of some types of capital equipment. However those factors don’t fully explain why lease penetration rates into larger firms seem to be very low indeed. The accounts of many FTSE companies show minimal use of equipment leasing, either on-balance sheet finance leases or operating leases reported in the notes to the accounts.

    There is scope for growing the market for small businesses. For example there is no comprehensive directory of places that small businesses can go to find asset finance. Asset Finance Policy’s new postcode-based listing of UK brokers (see a test version at www.assetfinance500.uk) is hopefully a small step in the right direction. I doubt however that even with improvements to how leasing is promoted to smaller businesses that we will see a substantial impact on industry growth.

    More significant progress both in the UK and across Europe seems to rest on our ability to grow the use of asset finance by listed and other large companies. These businesses know what leasing is and where to find it. What’s needed (as Mike called for in the interview) is innovation. We need to ensure that leasing isn’t just a form of finance to be compared against other forms of borrowing by corporate treasurers, but instead is seen as an innovative solution to reducing the total cost of use of key business equipment. That should be the focus for raising the industry’s profile and reach, as well as for preparing businesses using IFRS for the expected changes to lease accounting.

    Posted @ 15:43:33 on 22 September 2014
     

    Compulsory leasing that’s not at all bonkers

    In a Guardian article last Friday, Labour MP Dr Alan Whitehead argued the case for outlawing individual ownership of cars and forcing drivers to lease instead.

    This led to the inevitable Daily Mail article about Dr Whitehead’s mileage claims (apparently he once claimed £1.20 for a three mile trip, shock!). The Daily Mail reported that Transport Minister Robert Goodwill had described Dr Whitehead's plan as 'bonkers' and part of the Labour Party’s '13-year war' against motorists. Therese Coffey MP tweeted about Dr Whitehead being out of touch.

    Beyond this rhetoric, there’s an excellent point about leasing in Dr Whitehead’s article. We often argue that leasing is a ‘green’ alternative. We can already point to how leasing promotes the use of new and more efficient equipment, or how leasing companies recycle returned kit. However Dr Whitehead’s article brings a new and perhaps far more important argument.

    He notes that the AA puts the cost per mile of an average purchase price car at about 60p per mile.  The majority of this covers the cost of the vehicle, which is a fixed or sunk expense. The marginal cost per mile - which of course is what our driving habits are based on – is around 20p. If use of cars was based on a 60p per mile charge (which would be achieved through a leasing option with entirely usage-based pricing) we’re likely to change our choices and make more use of public transport.

    It’s sound logic, but the difficulty is how to lease on an entirely usage based pricing model. It’s offering the ultimate level of no-risk flexibility for the customer. It sounds impossible (even today’s car clubs don’t price this way) but the potential benefits to society  are huge. The value of such a model goes beyond the roads into other areas, such as making sure advanced medical equipment is available across the NHS. 

    A ‘green leasing’ solution is very likely to need Government backing (e.g. through guarantee structures covering minimum usage levels) but the cost to the taxpayer could be minimal compared to other ways of delivering the same goals.  

    Posted @ 20:51:51 on 14 September 2014
     

    FCA Full vs. Limited Permissions made simple

    The FCA has published a new decision tool to help firms decide whether they need full or limited consumer credit permissions. It’s a useful tool but the fact that there are 32 questions shows just how over-complicated the regulation has become.

    Posted @ 11:44:39 on 10 September 2014
     

    Who needs trade associations?

    In explaining its recent decision to leave the Association of British Insurers (ABI), Legal and General (previously the ABI’s third largest member) said it believed that in the future engagement with government, regulators and other external bodies will be more individually tailored, and less suited to uniform representation through one trade body.

    Under this logic, few large banks would remain members of trade associations including in the leasing industry. Each has its own political and corporate affairs departments. Regardless of the activities of their trade associations, they are busying lobbying on their own behalf.

    We might expect regulators and politicians to get frustrated, as it means yet more letters and meetings, but it’s often not like that - it can be more useful to hear specific concerns or suggestions from particular organisations than the rather bland missives that often result from associations finding a way to reflect the views of all of their members.  

    However trade associations shouldn’t be only - or perhaps even mostly - about lobbying. Their primary roles should be promoting high standards in their industries, promoting awareness of the usefulness of their members’ products and services, and providing services for members that help ensure the efficiency of the market. Those wider objectives should be equally relevant to members of all sizes.  

    Posted @ 17:10:19 on 23 August 2014
     

    Is the payday price cap an example of good regulation?

    The first post in this Blog on 15 March (see below) discussed payday loans. The idea was to test our theory that policy and regulation can work for finance providers and their customers. What better test, we asked, than the most problematic part of the UK’s lending market today: payday loans?

    We suggested that in setting a price cap for payday loans (as the FCA is required by law to do) the FCA could cap the maximum overall cost per payday loan. This would include the principal, interest and all fees, penalties and any other charges. We subsequently discussed this alternative - which as far we can tell hadn’t been considered before in the UK or other countries - with the FCA. We suggested it could be a better solution than an APR cap, working for both finance companies and their customers.

    The FCA has now issued its proposals for a payday price control. At the heart of them is a total cost cap, setting the maximum overall cost per payday loan at £200 per £100 borrowed. It could put an end to the (rare) horror stories of people borrowing £100 and ending up owning thousands.

    The FCA has gone further, however, proposing a £15 cap on default fees and a 0.8% per day total charges cap. A three-pronged price control feels heavy-handed and likely to make lending more difficult than the FCA’s analysis suggests. The FCA dismisses suggestions that borrowers will be driven to illegal loans. In our view it’s more likely that borrowers will instead be driven to longer-term but still very expensive loans outside the scope of the FCA’s remit.

    A good regulatory solution to payday is close. The onus is now on the payday industry to show why the total cost cap on its own is the best solution for both the industry and its customers.

    Posted @ 10:38:21 on 15 July 2014
     

    Where do UK companies fit in the European leasing industry?

    When Asset Finance International reported last week on the publication of the latest Leaseurope lessor rankings it highlighted the lack of participation of most UK lessors. All European leasing firms from Leaseurope’s 44 member associations are invited to participate in the annual survey, but only a couple of UK-based lessors do so: Bank of America (at position 28) and Asset Advantage Group (at 61).  

    Why does the UK appear to be so notable in its absence? One reason is that data for many UK lessors is already included in their European parents’ figures, including SG (the top ranking firm in Europe), ABN Amro, BNP Paribas, Caterpillar, Deutsche Leasing, DLL, RCI and Siemens. Perhaps there are concerns about confidentiality although league tables are common across other parts of the UK financial sector. Beyond that, it might simply be that not everyone is aware of the survey and how to participate in it.

    Asset Finance Policy wondered what the rankings would look like if more UK lessors were to participate. We dug out the latest publicly available annual reports of some UK lessors and estimated their total new asset finance business in 2013.

    Unless new business figures were available directly in the accounts, we took the leasing receivables, multiplied by 1.2 to convert to Euros, and divided by three as a rough stab at the ratio of new business to receivables.  This approach is likely to overstate new business volumes for banks with large big-ticket portfolios in run-off and understate volumes for faster-growing funders.

    Here’s the results of this back-of-the-envelope analysis using only publicly available data (so missing some lessors where we couldn’t track down the reports). In each case the position shown is where that lessor would slot into the Leaseurope new business rankings.

    Who’s missing from the Leaseurope top 60 rankings?

    Rank

    Lessor

    10

    RBS (Lombard on its own would be 17)

    12

    Lloyds

    16

    Barclays

    27

    Santander UK

    27

    Close

    32

    Aldermore

    55

    Investec

    57

    Clydesdale

    58

    Hitachi

     

    It appears that at least ten (and probably several more) UK-based lessors should be part of the Leaseurope top 60 rankings. Perhaps in the next survey some more UK firms will take part. There’s no charge, and those participating get to see extra tables showing equipment finance only (the rankings shown here include both business and consumer car finance as well as business equipment leases) and outstandings. See the Leaseurope website for details.

    Posted @ 11:20:13 on 06 July 2014
     

    A right royal accounting conundrum

    Her Majesty the Queen is leasing a luxury AgustaWestland helicopter for a year, it has been reported this week. The helicopter will bear the Royal crest and apparently will be used on a trial basis.

    According to the Daily Express, a spokesman for the Queen said the monarch had secured an annual lease for a helicopter, for a fixed number of hours. It represented good value for money because it will provide an alternative to chartering a number of different helicopters, the spokesman said.

    While everyone else consider matters such as whether this is Prince William’s birthday present, the hot topic in the leasing community is - naturally - the appropriate accounting treatment is for the Royal chopper.

    Some are debating whether this is really a lease or a service, given the report that it is based on a ‘fixed number of hours’ which seems to suggest it might actually be more of a service arrangement. It’s tricky however to imagine the royals sharing it with some other local families. The Royal crest also gives us a clue that this is indeed a dedicated asset. Besides, if Her Majesty is telling us that this is a lease, and that leasing represents good value, let’s not argue!  

    So to the heart of the issue. Will the chopper sit on Her Majesty’s balance sheet? Well stop the average tourist outside Buckingham Palace and ask them that question. They would think you are mad! Of course not they would answer in their many languages - It’s not the Queen’s helicopter, she’s just leased it for a year.

    Ah yes, but that just shows how few people have heard about the International Accounting Standards Board's planned new lease accounting rules. Assuming the lease is for a full year (and not some lesser period like - well - 364 days, because that just wouldn’t be worth worrying about, would it?) the Royal balance sheet would indeed need to show a new asset. OK, not actually the whole helicopter, but a chunk of it. Perhaps roughly equivalent to the tail boom and one of the rotor blades, possibly both. Some might argue it’s actually the tail boom, both rotor blades and also the chassis, because it seems there may be an option for the Queen to extend the lease. The Royal family is very unlikely however to need to worry about accounting for the cabin with the leather seats or the engine, and certainly not the tail fins.

    Why does the IASB think this is the right accounting treatment? Well, it’s not entirely clear. The rules have been under development for so long now no-one can quite remember what problem they were trying to solve. However the main thing is that the Queen is happy with her lease. Let’s just hope Her Majesty has accountants with time on their hands to sort out the Royal assets and liabilities.

    Posted @ 21:55:34 on 26 June 2014
     

    Peer to Peer for asset finance - The iceberg effect

    It’s difficult to see a place for peer-to-peer (P2P) lending platforms in the asset finance industry. However two presentations at a conference earlier this week on Financing SME Growth in the UK, organised by Middlesex University’s Centre for Enterprise and Economic Development Research, suggest we shouldn’t write-off P2P.

    How can a mostly unskilled (in asset finance) group of small investors make good lending decisions for leases? Why are the businesses seeking investment using the comparatively complicated and slow P2P route rather than going straight to a lessor? How well will the loan be managed? There are a host of concerns, heightened perhaps by the carrot of 6% or higher annual returns that may be dangled in front of investors and seem too good to be true (and probably are given they are based on small numbers of new agreements).

    There can be significant benefits to P2P, journalist Andy Davis explained at the conference. P2P platforms can be flexible, low cost and transparent. Unlike individual lenders, P2P platforms don’t have to worry about lending concentration risk, as individual investors take care of their own diversified portfolios. P2P also allows businesses to tap into their networks to help fund their growth.

    Returns on direct P2P investments will be tax free when included in ISAs from next April (although the details have still to be worked out) and ISA-ready funds investing through P2P platforms are already being launched.

    Jeff Lynn, CEO of P2P equity investment platform Seedrs, emphasised that a P2P operation is like an iceberg. It is less about the visible part - the website - and more about the deal and risk management that takes place underneath (and doesn’t come for free by any means, so expect more modest returns). The key requirement is to build and maintain investors’ trust in the platform.  

    An equivalent of Seedrs for asset finance - where the credit assessment and management of the book on behalf of investors is nothing less than best in class across the industry - could work and be the start of something big.

    Posted @ 17:48:04 on 05 June 2014
     

    Keeping consumer credit regulation in perspective

    Regulated consumer credit agreements - now regulated by the Financial Conduct Authority - are only a small part of the asset finance market. Many funders have long-standing policies of working only with limited companies. Others are now implementing such policies for all or some of their market segments. Probably around 5% of the market by value is regulated business, although this probably equates to 20% of the market by number of agreements.

    However for many asset finance intermediaries and funders dealing with the new FCA consumer credit regulation is, or is about to, take a lot of management time. Regardless of whether a broker, vendor or funder is writing ten regulated agreements a year or ten thousand, they now have the same FCA regulatory mountain to climb.

    There are practical solutions. The most obvious is simply for more firms to join those moving away from regulated agreements. Most non-incorporated businesses are very small and - research shows - unlikely to need to lease equipment. There are already 1.4 million small companies in the UK and the number is growing. Setting up a company takes around twenty minutes on the Companies House website, costs £15, and can save £ thousands per year in tax for a profitable business.

    However leaving the regulated sector certainly won’t be desirable or practical for all, so what are the alternatives?

    As we get closer to the “landing slots” (application periods and deadlines) for FCA applications for most asset finance players, perhaps we will see smaller intermediaries become agents or introducer appointed representatives, passing business to larger brokers that can cope with the full regulation. The arrangements work well in other parts of the financial sector but they would need the support of the funders. This may be important in keeping some of our most experienced and skilled brokers in the market.

    For those that are left in the FCA authorisation process, there should be no need to reinvent too many wheels. Help is available with implementing regulatory policies and procedures that will meet FCA requirements, including from lawyers or consultants of course, but also specialist online support services (Asset Finance Policy is working with one). It’s still a major task but one that can be achieved in far less time and often more effectively than going it alone.  

    The new regime is far from perfect and it’s clearly designed to control the payday and other high-cost consumer credit areas and not asset finance. However we have to accept it for what it is and find practical solutions, to ensure that some of our most valued intermediaries stay in the market, and to ensure that we can continue to offer excellent deals to the hundreds of thousands of small businesses across the UK that benefit by using asset finance. We’d be pleased to discuss any aspect of this with you.

    Posted @ 09:31:21 on 14 May 2014
     

    Delivering the potential of asset finance - are we ready?

    The Bank of England’s Agents’ Summary of Business Conditions, out today, reports that small firms, particularly those short of unencumbered assets, continue to find the availability of bank lending tight. However, asset finance was reported to have become increasingly available.

    The ability of the leasing industry to lend when others can’t is increasingly recognised in Government. It’s a key reason why asset finance is a priority for the Government’s British Bank. Another report out today, the Department for Business’s progress report on its Industrial Strategy, highlights asset finance as one of the alternatives to conventional bank lending that the British Business Bank is supporting.

    Last week the latest round of successful bidders for the Government’s Regional Growth Fund (RGF) was announced. Compass Business Finance, Close and RBS were included in the fifth round. Several other asset finance providers are also already using the RGF to support additional investments by hundreds of SMEs.

    If there was any doubt about the growing relevance of asset finance, don’t miss Leaseurope’s new publication, European Leasing: An Industry ‘Prospectus’. This neatly sets out the case for leasing to investors, parent banks and manufacturers with some powerful data.

    It all seems very positive, but are we yet in a position to deliver the considerable potential of leasing to support the economic recovery?  Our counterparts in the US, Canada and elsewhere seem to share a lot more information than us to help them to manage their businesses and attract funding, whether that’s about operational benchmarks such as staff compensation, performance benchmarks such as return on assets, or loan performance data such as default levels.  They also work together to actively promote leasing to small businesses.

    These are areas where greater collaboration across the industry could deliver significant benefits to both finance companies and their customers. We'll write more about them in future blogs. In the meantime do post your views or contact us to discuss.

    Posted @ 19:35:12 on 23 April 2014 
     

    A GAAR for the credit industry?

    At last weeks’ Credit Today Summit, it’s reported that speaker John Lamidey asked the delegates to imagine a High Street where kebab shops were regulated like alternative lenders. Customers could only buy two kebabs a month, the kebab shops would carry out affordability checks on their customers’ finances, and shops would display huge signs saying kebabs make you obese.

    Whilst possibly not the most sensitive comparison to make (as was quickly pointed out by at least one payday campaigner on Twitter) it’s a fair point. The regulation of credit is quite extraordinarily detailed - to the point that even the most diligent and responsible lenders and brokers struggle to make sense of it all.

    It’s not a great place to be. This is what develops over a long period of time when there’s a breakdown of trust between policy makers and companies in a market. It’s the same problem that has led to the UK’s voluminous tax regulation, with huge swathes of it put in place over many years to deal with tax avoidance schemes.

    Can trust be repaired? A possible answer in the tax system has been the new General Anti-Abuse Rule (GAAR), aimed at deterring and preventing artificial and abusive tax avoidance schemes. Introduced into law by Finance Bill 2013, the GAAR catches “abusive” tax planning or arrangements that fail to pass the ‘double reasonableness’ test – those that “cannot reasonably be regarded as a reasonable course of action.” The GAAR draws a clearer line between tax minimisation and tax avoidance, removing some of the heat from the issue.  

    If the GAAR is found to help address tax avoidance (it’s too early to form any reliable view) it could, in the long term, facilitate a major simplification of the tax regulation. Is there an equivalent for the credit market - a simpler test of whether credit practices are on the right side of the line? Given the alternative of ever-increasingly detailed regulation it seems worth exploring.

    Posted @ 20:15:37 on 06 April 2014
     

    Small business banking - why Captain Mainwaring can’t help any more than new legislation

    Another month, another Government consultation on SME finance.

    At the Federation of Small Businesses’ conference in Manchester on Friday, George Osborne announced a consultation on possible new legislation to force banks to introduce the businesses they reject for loans to smaller finance providers.

    This comes hot on the heels of a consultation on plans to force banks to share business current account data with other finance providers. The draft legislation is expected soon.

    Meanwhile the Competition and Markets Authority is considering whether to launch a detailed investigation of the retail banking market. Should the CMA to go down that route - which seems more than likely - expect recommendations in 2016 and yet more legislation in 2017.  

    It’s all about creating a more diversified SME banking market, which is a good objective. It’s a lost cause to suggest - as the Chancellor is reported to have done - that banks go back in time to the ‘Captain Mainwaring’ style of local bank manager who can somehow magic up a low-cost loan to all local businesses. Whether it’s driven by tighter capital requirements regulation, or a focus on profitability, Captain Mainwaring’s style doesn’t fit with what banks do today.

    However is the road to a more diversified SME banking model built on legislation? We doubt it.

    Non-banks already have access to business current account data. They can ask to see an applicant’s bank statements. Indeed many quite like it that way, so they see the details rather than some Government-concocted high-level summary as is being planned through legislation. Non-banks are also hardly jostling in line to be sent customers that the banks have just rejected.

    The challenge is how to get more investment into the non-bank SME finance providers to enable them to grow faster.  

    There are major obstacles to the growth of the non-bank sector today. One is the weakness of data on SME loan performance in the UK that makes it so hard for fund managers to commit the savings and pensions entrusted to them. Another is a lack of information available to SMEs on exactly where to turn to find the full range of financing options. Last but certainly not least are the distortions caused by the Government’s programme for pumping cheap money into the market almost exclusively through the banks.

    It is these macro issues limiting the non-bank SME finance sector - not the details such as business current account data sharing or referral mechanisms - which should be the priority for the Chancellor. We’ll be saying more about how to overcome the issues in future entries in this blog. As always, we’d be very interested in your views.

    Posted @ 15:18:14 on 29 March 2014 
     

    Getting investment support to where it’s needed

    In his Budget speech, the Chancellor announced the doubling of first year capital allowances to £500,000. 99.8% of businesses would get a 100% investment allowance, he said.

    Did he mean that 99.8% of businesses have taxable profits against which their investment can be offset? If only British businesses were doing that well! Or did he mean that 99.8% of businesses that are expected to invest have taxable profits? How alarming would that be? It would suggest that hardly any businesses that aren’t already profitable are expected to invest.  I imagine he really just meant that 99.8% of businesses invest no more than £500,000 per year.

    From a policy perspective the problem is that the businesses that need the most help to invest are precisely the ones that don’t already have healthy taxable profits. Which is why it makes more sense to promote investment through the leasing industry.

    Hidden away in yesterday’s announcements there’s a glimmer of hope on this front. The Chancellor announced that the Office of Tax Simplification had published a call for evidence on its review of competitiveness of UK tax administration. This is a wide-ranging review looking at all ways of reducing tax administration burdens on UK businesses and capital allowances are clearly in scope with a particular focus on how they affect small companies.

    This may not sound exciting, but it could be important. After a bit of a slow start, the OTS is now having a big impact on tax policy. It will be important for the leasing industry to make a strong case to the OTS for simpler and more flexible taxation for leasing, helping to ensure that in future capital allowances can support investment by businesses that most need help and not only businesses that already have plentiful taxable profits.

    Posted @ 18:14:02 on 20 March 2014 
     

    How Do You Solve A Problem Like Payday?

    This first post is designed to test our theory that policy and regulation can work for finance providers and their customers. What better test than the most problematic part of the UK’s lending market today: payday loans?

    Last month the Competition Commission published new research on the market. It found over a million people use payday loans. The average loan is around £260, for an average of 22 days. Two-thirds of loans are repaid on time or early, many others are repaid only slightly late. What’s not to like?

    It doesn’t help that the industry’s selling and debt collection practices have been of mixed quality. A raft of new regulation is addressing that. Payday loans are also far from cheap, typically 1000% to 6000% APR, but of course APR’s are difficult to interpret for very short loans.

    The heart of the problem however seems to be that some borrowers - probably only a small minority - can end up owing many thousands of pounds having taken out only a small loan. This is because of the compounding effect when loans are refinanced (either ‘rolled-over’ with the same provider, or more likely as new loans with new providers).  

    The FCA now has to impose a cap on the cost of payday loans by 2 January 2015, in addition to other new regulatory measures. It will consult on proposals for the cap this summer. It’s already clear the cap will take account of the “overall cost of credit”, so including all fees as well as interest.

    Could a rate cap work for both payday finance providers and their customers? It seems unlikely. The cost of providing many payday loans would suggest APR’s far higher than 100%. A lower APR cap - or even an overall cost of credit cap that isn’t annualised - would severely restrict the market. A higher cap meanwhile wouldn’t be seen as protecting customers, as borrowers could still end up with high debts.

    There might be a better policy solution. Instead of capping the rate, the FCA (or the Competition and Markets Authority) could cap the maximum overall cost per payday loan. This would include the principal, interest and all fees, penalties and any other charges. It wouldn’t be a percentage cap, or a cap per £100 of loan, it would simply be a fixed total maximum cost in pounds.

    The maximum overall cost per loan might be set at, say, £400. Or there might be two levels: say £300 maximum for most loans; and a £500 maximum for loans to users who repay on time every time and have only one payday loan with any provider.

    We think this alternative - which as far as we can tell hasn’t been considered before in the UK or other countries - could address the worst problems in the market whilst allowing the market to continue to function. It could work for both finance providers and their customers.

    Do email if you would like a copy of our briefing on this. We’d be very interested in your views.

    Posted @ 10:47:56 on 15 March 2014 

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