There was a full agenda for our March Board meeting and we covered a lot of ground.
The team is making real progress on many different fronts, as we gear up to launching our new standards and becoming fully operational later this year.
We began the meeting with a paper on the draft budget and levy proposal – an update to our discussion in January. The Board ultimately agreed to consult on a budget of £1,188,000 and a levy of between 0.44-0.45% of turnover.
Following the meeting, our draft business plan consultation is now live and sets out the detail behind our workplan, budget and levy calculations. I really hope that people will review our plans and let us know what they think.
We then moved on to discuss statutory underpinning, as the MoJ is soon to begin its review of whether to give the ECB statutory powers.
Previously, the Board agreed that it is in favour of seeking targeted statutory powers that would help us to pursue our mission efficiently, without affecting our independence or ability to be fleet of foot. This subsequent discussion was an opportunity to consider what specific targeted powers we might seek through the review.
We concluded that the most important powers would be a statutory power to make it mandatory for both firms and agents to be authorised by the ECB if they wish to work in enforcement. There are also some specific powers that would ideally supplement this, such as information sharing powers, or the ability to seek to extend or amend the ECB’s scope. This discussion proved incredibly topical as at the weekend, the case for giving the ECB statutory powers was featured in an episode of BBC Radio 4’s Moneybox programme (https://www.bbc.co.uk/sounds/play/m001x48c).
The Board then discussed and agreed the scope of the ECB’s independent complaints handling function, which will be published on our website in the next few weeks. The scope will set out the role that the ECB will play in improving first stage complaints handling through our standards and in establishing a new independent second stage complaints function for cases where people feel their complaint hasn’t been dealt with fairly by the firm in question.
The Board agreed that our complaints handling function will launch in January 2025, a couple of months after we launch our new standards.
Our discussion about complaints was wide ranging and we also discussed the pros and cons of the ECB hearing historic complaints.
We noted that it would not be safe to assess historic cases against the ECB’s new standards, which would not have been in force, and that there may be difficulties in accessing the underlying evidence from body worn video.
Ultimately, we concluded that the ECB will only hear complaints that arise after our own scheme has gone live. This will allow us to assess all complaints against the ECB’s new standards, which will also include requirements around retention of body worn video recordings to assist with determination of complaints. We recognise that this will be disappointing for some people with existing or historic complaints – but it is important that we set our new scheme up to succeed.
We also discussed the development of ECB’s standards, following January Board’s agreement on the project’s scope.
We talked about the progress that has been made in beginning our programme of stakeholder engagement on the standards, including the upcoming workshops with agents which are currently open for sign up. https://enforcementconductboard.org/standards/
We also discussed some of the big policy choices that need to be taken as we draft the new standards, particularly on vulnerability and affordability and the need to ensure that we are testing our policies with the enforcement and debt advice sector so that we can be confident they work in practice.
I’m looking forward to discussing these important issues further at future Board meetings, as the team develops the detail of the proposed standards.