The BSA has responded to the FCA's emergency consultation on proposals for temporary relief for consumer credit borrowers affected by the COVID-19 pandemic. The proposals, issued on 2 April for comment by 9 am on 6 April, cover overdrafts, credit cards, and personal loans that are regulated agreements. The BSA supports the FCA’s objective of providing temporary support to borrowers affected by the lockdown measures taken to combat the coronavirus pandemic, and has made two separate responses. The first covers the proposals as a whole from the perspective of BSA members generally. The second, submitted through the National Credit Union Forum (now the credit union committee of the BSA), specifically addresses the situation of credit union loans. Both responses can be read below.
General response : we comment on the start date, the end of the relief, and technical compliance with the Consumer Credit Act. BSA supports the more detailed response from UK Finance. BSA contact - Elaine Morton
Credit union specific response : we support the FCA's focus on regulated agreements, meaning that credit union loans are out of scope but borrowers will be helped by credit unions' established approach to those in financial difficulties. BSA contact - Jeremy Palmer