FCA – regulated & Levies – Rates proposals 2016-17
Having consulted with ABCUL’s membership which represents around two thirds of all credit unions which are affiliated to a trade body, we are pleased to confirm our support for the rates proposals as published.
In particular, we support the FCA’s commitment to proportionality as represented by its maintenance of the minimum fee rates. These minimum fee rates – and in particular the special minimum fees available to small credit unions – are key to supporting the development and maturation of credit unions prior to contributing on the same basis as other firms once they reach certain scale. We appreciate the ongoing recognition that this fee regime for credit unions represents as to the social role credit unions play in extending access to affordable and appropriate financial services.
Furthermore, we support the proposed new authorisation fee for new start credit unions which, in light of the abolition of Version 1 and Version 2 credit unions, sets the authorisation fee at the level previously reserved for Version 1 credit unions. Once again, this recognises credit unions’ need for proportionality – particularly in their early development – and we appreciate this ongoing support for the sector.
We do have come concerns in respect of the debt advice levy for the Money Advice Service in that it continues to not raise any funding from the consumer credit sector. While we appreciate that this would be a matter of fees policy, rather than rate, we use the opportunity of this consultation to make the point that we have consistently made which is that those consumer credit companies which contribute significantly to problem debt ought to be required to contribute to the costs of the debt advice levy on a “polluter pays” principle.
On a more positive note we continue to support the case fee regime for the Financial Ombudsman Service whereby only those that receive 25 complaints or more in the year contribute to this levy. This is a fair approach which ensures only the most complained about firms contribute to the Ombudsman’s costs.
We appreciate the opportunity to respond to this consultation and would be very happy to answer any questions you may have.