Chief Executive’s Report, July 2024

Introduction

  1. The last six weeks have been mainly focused on extensive engagement with stakeholders on our draft ECB standards for enforcement. We’ve had well attended and really valuable workshops with debt advisers and enforcement firms, to supplement the targeted research we undertook earlier this year with individual enforcement agents. We have also completed a big and productive round of engagement with creditors through the IRRV regional forums.

  2. It has been extremely encouraging that so many people with a stake in the sector have been willing to give us their time and share their feedback on our developing plans in this area. The feedback has been constructive and encouraging and we remain on track to launch our public consultation on the draft standards by the end of July.

  3. The team has done a great job in putting together the materials and leading these engagements, covering significant miles by train and car to do as many engagements as possible in person, across England and Wales.

  4. More recently of course, our attention has also turned to building relationships with the new administration, ensuring that we do not lose any momentum in the short term and laying the groundwork for future progress and partnership working with the Ministry of Justice, in pursuit of our mission. The Board is discussing this very subject in North Wales when we meet.

Current cash position and finance management

  1. The cash position at the 10 July was approximately £716.5k against a predicted balance of £1.14m. This variance is due to a slight extension of the window for levy payments from the largest enforcement firms, and one staged payment arrangement being agreed. Taking account of this, the cash position remains where we expect it to be and there are no concerns.

  2. The Board will be presented at the meeting with two finance papers, the final Quarterly Financial Report for 2023/24 and the ECB’s Annual Accounts which will need to be agreed by the Board before being filed with Companies House at the end of the month.

  3. Regarding the decision to move bank, which was communicated to the Board last meeting, we have been researching different products and seeking opinions from our network as to our best options. We have narrowed it down to two options, with the current preferred option appearing to have the most functionality online (without the constant need for wet signatures). A final decision will be made by the end of the month with the transfer happening in early August.

Recruitment

  1. We have three new roles coming up over the next year: administrative officer, complaints investigator and a supervision manager.

  2. We have recently agreed a recruitment timetable for the administrative office with our recruitment partners, Diversify. We hope to launch recruitment for the role towards the end of Summer and have a chosen candidate by the end of September.

  3. We are also working on the job description for the Complaints Investigator position which we hope to recruit to over the summer.

Accreditation and the levy

  1. In June we issued levy requests to the eight largest enforcement firms by turnover. We are expecting the final few payments imminently.

  2. Board members are reminded that we have agreed a levy of 0.44% of turnover (from TCOG fees) for this year. Requests to all remaining accredited firms will go out in Autumn this year.

Research and evidence

  1. The Director of Creditors and Government will update the Board at the meeting with the very latest on the ECB BWV research project, prior to the interim report being delivered within the next month.

Data Returns

  1. Following the successful introduction of the 2024-25 Data Return system on 1 April, all accredited firms will now be collecting data for the first return due by the end of October. The Director of Creditors and Government has held the first of several Q&A Drop-In sessions for firms to answer any queries and deal with any teething issues. There were no significant problems reported by the industry with the ECB’s DR requirements, with most of the issues raised being technical. The Managing Director of Rundles has offered to chair an industry meeting to establish if a software solution can be found to help firms to collate and load the DR information in a simple and unform way.

ECB Standards Development

  1. Since the last Board meeting the team has carried out four workshops with accredited enforcement firms, using the targeted engagement paper that the Board reviewed when it last met. The insight provided in these sessions has been invaluable and the standards have been well received overall.

  2. Following the success of the debt advisor workshops that took place last month, the team are currently arranging further sessions with in-person community money advice organisations to discuss the standards.

  3. The Board has a paper on the agenda setting our the proposed amendments and improvements that we propose to the draft standards to reflect the feedback received from the industry and debt advice workshops.

  4. Thinks Insight, who we contracted to carry out workshops with enforcement firms and those with lived experience of enforcement action delivered their final report on the findings of this research in May. We are now working with the team at Thinks Insight to prepare an executive summary of their work which we will look to publish later in the year.

Complaints handling

  1. Our efforts have been focussed on drafting the complaint standards and developing the framework for the accompanying guidance. This has fed into the workshops with accredited firms.

  2. We have continued to engage with CIVEA and HCEOA, including meeting with two of CIVEA CARE panel members. Engagement with the big 8 firms is going well, having met with half of their complaints teams so far. Engagement with the medium and smaller sized firms has taken a bit longer to get going but we will be meeting with a number of them over the next month or so.

  3. We have spoken with four local authorities so far to get a better understanding of the complaints process from a local authority perspective and have more meetings planned. In terms of statutory Ombudsman schemes, we are engaging with them to talk about overlaps in our jurisdictions and sharing information. We are continuing to engage with LGSCO and have meetings in place with OPHSO and FOS. We are also in contact with the Ombudsman for Wales, the Energy Ombudsman, the Communications Ombudsman and the Consumer Council for Water to set up meetings with them.

  4. We are also beginning to think about further recruitment to the Complaints Team and are working on the job description for the Complaints Investigator position.

Creditor engagement

The main focus of our creditor engagement during the period has with local authorities at the Institute of Revenues, Rating and Valuation (IRRV) summer fora.

This is a major undertaking, involving the Director of Creditors and Government, CEO and Director of Policy and Oversight speaking at a series of regional IRRV events across the country during June about the work of the ECB, the creation of our oversight framework in 2024/25 and our plans to invite local authority in-house enforcement services to apply for accreditation in the autumn. Together, we spoke to over 130 councils along with enforcement firms, policy groups and voluntary organisations. A number of the councils with in-house teams expressed interest in accreditation, and saw it as attractive for councils, but consistently raised questions about the cost of the proposed ECB levy and how our complaints function would work alongside the statutory role of the Local Government Ombudsman. These issues are covered in greater detail in the separate paper on in-house accreditation being presented at the July Board.


Overall, the IRRV events were a highly successful and effective way of getting the ECB word out there, with a lot of positive feedback about the ECB and its willingness to engage with councils. The DCG also used these events as an opportunity to visit 4 enforcement firms during the Midlands and East Anglia IRRV events.

Communications and Engagement

  1. As discussed at April Board, the communications team are overseeing work to optimise the current iteration of our website which includes embedding content from PDFs and the creation of a Welsh language version. The project will now turn its attention to SEO work.

  2. The communications team has also started work on scoping a potential wider website/brand project as part of our thinking for Communications and Engagement in 2025/26, with an eye to functionality and accessibility and members of the public start to use our website more frequently.

  3. The team are also engaged in proactive planning for the publication of Standards and Complaints.


    Political strategy and public affairs

  4. As agreed at the April Board meeting, we have spent some time reflecting on our political strategy and public affairs work. Having undertaken internal team workshops and having had discussions with two public affairs agencies and one freelance public affairs expert, we have contracted Joe Shalam (who Chaired the working group that developed the blueprint for the ECB) to lead a quick turnaround piece of public affairs work which will be discussed at July board.


    Engagement and learning

  5. We have had a number of meetings with the Security Industry Authority about potential synergies and learning opportunities between our organisations, as well as the enforcement team at the BBC.

  6. The Director of Policy and Oversight presented on the development of the standards to the Regulators Network Vulnerability Academy which is made up of vulnerability experts from across a number of different regulators and oversight bodies

  7. We have also had conversations with a number of oversight bodies and industry bodies to inform development of our complaints function and standards including:
    a. The ICO
    b. The Financial Ombudsman Service
    c. The Parliamentary and Health Services Ombudsman
    d. The Consumer Council for Water and Energy UK
    e. The Lending Standards Board
    f. The Insolvency Service

  8. Over the coming month, the team have planned the following engagements:

Upcoming engagement

• A meeting of our stakeholder engagement forum


• Workshops on the standards with in-person community money advice organisations


• The DCG is keeping in close touch with the Enforcement Policy team at the Ministry of Justice to understand (and help shape where necessary) officials’ advice to new Ministers about enforcement, including on ECB statutory underpinning. Given other pressing MoJ priorities and decisions, this advice may not be seen by new Ministers until later in July.


• The Director of Policy and Oversight and Director of Creditors and Government are attending the LACEF conference, speaking on a panel discussion with LGSCO and CIVEA about the interaction between the three organisations.


• On the morning of the Board (Weds) the DCG will be visiting a small North Wales firm.


• Further shadowing of enforcement agents and visits to enforcement firms

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