Chief Executive’s Report, June 2024

Introduction

  1. I draft this month’s report in the wake of the announcement of a General Election on 4 June. This news came the day before we had a team office day in Birmingham, which allowed us to consider the implications of this for the ECB, enforcement sector and our mission. I will set out our current thinking for the Board at the meeting. We will be continuing to build on this over the coming weeks, to ensure that we are well placed to seize the opportunities that this news creates as well as being on the front foot in managing some of the risks.

Current cash position and finance management

  1. The cash position at the 22 May was approximately £352k. This compares very favourably to the expected cash balance set out in the budget (£203k), but this is largely due to a combination of some regular monthly payments not being paid yet (including approximately £40k of salary), research work and legal fees being invoiced later than expected, end of year accruals and some underspend. If the change in project timelines, and therefore invoices, continues to affect our cashflow predictions beyond the quarter, we will run another cashflow projection with the new dates factored in.

  2. Our external accountants have recently finished finalising the ECB’s end of year accounts, including reconciling the accruals, and have recommended that we submit our Annual Accounts to Companies House early this year (last year we submitted in October). Therefore, instead of receiving the Quarter Four Financial Report this month as was scheduled, we will present the Board with the end of year accounts, and Directors’ Report for signing off at the July meeting which will cover all the same material. The headline of the Quarter Four accounting period is that total expenditure for the year to 31 March was £750k against an approved budget of £820k for the same period. This was a £70k underspend across the year. We had factored an underspend in this region into our budgeting for 2024/25.

  3. We have also taken the decision to switch banks. We have found our current provider to be administratively burdensome to work with, with the majority of their account management requiring handwritten, posted forms. We are currently exploring our options and have identified two providers that appear to offer a much more modern system including account management via an app and multiple linked bank accounts which will allow us to set up a separate reserves account and expenses account with capped debit cards.

Recruitment

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

  2. For the first role we will be partnering with a specialist recruitment agency focused on supporting diverse and inclusive recruitment campaigns and, from previous recruitments rounds, we know that this targeted help will be valuable in helping us to secure a strong and diverse shortlist.

Accreditation and the levy

  1. We will soon begin issuing levy requests to the 8 largest enforcement firms by turnover. Board members are reminded that we have agreed a levy of 0.44% of turnover (from TCOG fees) for this year.

  2. 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 4 June meeting with the very latest on the ECB BWV research project. At the time of writing this, all documentation – Data Sharing Agreement and Privacy Policies – has been agreed by the industry. M.E.L have contacted all firms and are now scheduling in fieldwork visits from June.

Quarterly 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 will be scheduling Q&A Drop-In sessions for firms in June to answer any queries and deal with any teething issues.

ECB Standards Development

  1. The team has carried out workshops on some high-level standards ideas with debt advisors at Money Advice Trust, Step Change and Christians Against Poverty. The insight provided in these sessions has been invaluable and the team plan to carry out a further workshop with community-based debt advisors within the month.

  2. Thinks Insight, who we contracted to carry out workshops with enforcement firms and those with lived experience of enforcement action have delivered their final report on the findings of this research. The team at Thinks Insight are currently preparing an executive summary on these findings and this will be published on our website within the month.

Complaints handling

  1. Claire Evans has now joined us as Complaints Manager (part time until June). Her time this month has focussed on learning about the various complaints processes and the enforcement landscape.

  2. Claire has met with CIVEA and is working with them to identify enforcement firms of different sizes for her to engage with and learn more about complaints handling now.

  3. Claire is also meeting with HCEOA on 30 May and Is scheduling visits to complaints teams at a number of enforcement firms.

  4. This will feed into the work on developing the Complaints Standards.

Creditor engagement

  1. Following the prioritisation of work on BWV Research and QDR, the Director of Creditors and Government has now resumed proactive creditor liaison. The DCG had successful meetings with TfL and the Highways Agency (who run the Dart Charge) and will be able to update the Board at its meeting. He has also scheduled initial meetings with government departments which use enforcement, specifically HMRC and DWP. He is also engaging the West Midlands Revenues and Benefits Group – a collection of West Mids Councils – on the issue of in-house accreditation, and is reinstigating engagement with energy companies following Ofgem’s endorsement of ECB accreditation.

  2. The biggest recent success is with the Yorkshire Purchasing Organisation, one of the country’s biggest public sector procurement organisations (and responsible for 75% of all competitions run by local authorities for external enforcement). From May 2024, all enforcement firms wishing to bid for local authority contracts through the YPO framework must be accredited by the ECB (whose logo and details are prominent on the YPO website). This is significant because, while all enforcement firms on the YPO framework are currently accredited, should any of them seek in the future to withdraw from ECB oversight, they will lose the right to bid for local authority work.

Communications and engagement

  1. Our proactive communications activity this month has been focussed on beginning to implement some of the priorities outlined in the communications and engagement plan for 2024/25, which was reviewed by the Board last month.

  2. Publication of our final business plan and response to our consultation went smoothly. The team has also prepared a number of articles for regular publications including the High Court Enforcement officers Association (HCEOA) newsletter and CIVEA’s ‘enforcement news’.

  3. I spoke at the HCEOA AGM in Birmingham and the IRRV Spring Conference in Milton Keynes. Both events were well attended and included thoughtful questions and discussion. Both provided an opportunity to reflect on the progress made since the same conference the previous year. I was also interviewed for a piece on the use of enforcement agents collecting Council Tax debt for Leading Britain’s Conversation (LBC) online.

  4. The ECB, through the DCG, continues to be active on the judge-led Civil Justice Council Enforcement Working Group, which is focusing on court processes and impediments for enforcement methods which do not require taking control of goods, e.g. attachment of earnings etc. Prior to the announcement of the general election, the CJC WG was planning to issue its own call for evidence in the summer.

  5. We have made progress on development of a targeted engagement strategy to ensure that the ECB is near the tope of the agenda


    Political strategy and public affairs

  6. As agreed at the April Board meeting, we are developing a paper for the Board on our political strategy and public affairs work, including key stakeholders and how we might seek to secure their support. So far, we have undertaken workshops on this with the team. We have also had initial discussions with two public affairs agencies and one freelance public affairs expert about how they might provide some targeted strategic advice and support to us in relation to this.

  7. At our team office day on 23 May we discussed how the announcement of an imminent General Election impacts on this work, which I will discuss with the Board when we meet. Taking all of this into account, we plan to present a paper to the Board in July.

Upcoming engagement

  1. Over the coming month, the team have planned the following engagements:
  • Workshops with accredited enforcement firms on standards
  • Workshops with community based debt advisors on standards
  • Attending the June meeting of the CIVEA Executive Council
  • The CEO and DCG will be speaking at a series of regional fora in June and July run by the Institute of Revenues, Rating and Valuation, an influential body on local authority enforcement.
  • The DCG will also be presenting at the Enforcement Law Reform Group chaired by Lord Lucas in the Lord on 13 June, possibly the last ELRG before the election
  • Spending time at call centres of accredited firms and further time shadowing enforcement agents.
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