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BSA responds to FCA CP26/7 Credit Information Market Study: Proposed approach to implementing FCA remedies

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 all 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 also potential for increasing costs over time as challenger CRAs seek designation. We are concerned that this is not a suitable ‘future-proofed’ long-term solution. 
  • We call for the FCA to carefully consider the proportionality of their 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 to not prohibit DCCRAs from levying charges. We believe that this is an essential requirement to protect firms, to ensure all firms can participate fairly and avoid any possible market interference.