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BSA responds to FCA CP26/7 Credit Information Market Study Consultation

The BSA responded to the FCA's CP26/7: Credit Information Market Study Consultation, which can be found here. 
The BSA responds to the FCA's CP26/7: Credit Information Market Study Consultation, which can be found here. 

The BSA welcomes the FCA's aims to deliver a well-functioning credit market that supports improving consumer outcomes. We note however:
  • We are concerned that initial engagement with the new Credit Information Governance Body (CIGB) has not been consistent with its intended principles of inclusivity, transparency and accountability. We call for stronger co-ordination between the CIGB and the FCA going forward. 
  • The FCA proposes to designate the largest three credit reference agencies (CRAs), which participating firms will then need to set up contracts with. We raise concerns that there has not been great enough attention paid to proportionality with this proposed remedy, given the highly variable size and resource of firms across the market. There is potential for increasing costs over time as challenger CRAs may seek designation.
  • We call for the FCA to carefully consider the proportionality of the remedies, with additional expectations and reduced timescales likely to be operationally challenging for smaller firms. We support longer lead times and transitionary periods. 
  • We raise concerns with the proposal not to prohibit DCCRAs from levying charges. We believe that this is an essential requirement to protect firms, ensuring fair participation and avoiding future possible market interference.