Chief Executive’s Report, October 2024

Introduction

  1. The theme for this month has been consultation, as we have been analysing the many responses we received to our recent standards consultation, whilst also preparing for our next consultation on complaints and sanctions. Alongside this, the team has been preparing for the launch of the process for re-accreditation for Year 2 at the end of the month, including launching our offer for
    in-house teams.

  2. There’s still a lot to do but we’re currently well placed to meet the big milestones ahead and be ready to start full operational oversight from the turn of the year.

Current cash position and finance management

  1. The cash position at the 1 October was approximately £824k against a predicted balance of £843k. This variance is largely due to a staged payment arrangement being agreed with one of the largest firms. The mid-year reforecast will be presented to the Board during this meeting and the cashflow predictions going forward will take into account these staged payments.

  2. The Executive have taken the decision to switch the ECB’s account. Due to the time required for the switch process we have decided that it would be prudent to wait until after the second round of levy collection and the ECB logo fee collection. We will be looking to make the switch early in January.

Recruitment

  1. We have had a successful month of recruitment with both the administrative officer and complaints investigator roles filled, with our new colleagues due to join us in late October and mid-November respectively. We are very happy with our chosen candidates and are looking forward to getting them up to speed and contributing to the team.

  2. We have two further recruitment campaigns currently underway. The first is for a Director/Head of External Affairs and the other for the Policy Manager. Two more essential roles in the structure of the ECB. We are hoping to have these roles filled by January 2025.

Accreditation and the levy

  1. In June we issued levy requests to the eight largest enforcement firms by turnover.

  2. We are now proceeding with issuing requests to all remaining accredited firms, for payment by 31st October.

Research and evidence

  1. We hope to publish the final report by the end of October, either prior to, or alongside, the publication of the standards.

  2. We have received the final report from our research partner, M.E.L on the BWV research project. The full findings will be presented to the Board during this session.

ECB Standards Development

  1. The standards consultation closed on the 13 September, and we received 46 formal responses from debt advice, the enforcement sector, creditors, local authorities, membership bodies, ombudsman and private individuals. The high quality of responses reflected strong engagement from our stakeholders, both in terms of substance and detail.

  2. We have also continued our targeted engagement, running a number of workshops with debt advisors from Citizens Advice and local money adviser networks. This engagement has been invaluable and has continued to inform our thinking as we head towards publication of the standards.

  3. The Board has a separate paper on the consultation and our draft response to it. We intend to publish the standards, and accompanying guidance by the end of October.

Complaints handling

  1. Our efforts this month have focused on developing the ECB’s Guide to Remedy. To help with this important work we have set up a working group with representatives from the sector and debt advice. We will be continuing to work with them on developing the framework for consolatory payments for non-financial loss.

  2. Following the special Board meeting on 26 September, we are on track to publish the Guide, together with the ECB’s Complaints Process, the ECB’s Decision Review Process and the Guidance that accompanies the standards on complaints on 10 October.

Creditor engagement

  1. The ECB has continued to discuss with councils its proposal to invite accreditation of council in-house enforcement teams for the first time when the ECB window opens at the end of October.

  2. The Director of Creditors and Government (DCG) has recently engaged directly with several possible candidates for early accreditation in England. For Wales, on 26 September the DCG addressed the Welsh Revenue and Benefits Conference, attended by all 22 Welsh councils, with the aim of generating further interest in accreditation for in-house teams. We also continue to engage with the Welsh LGA.

  3. Our offer to councils includes the two policy decisions made by the Board in Hawarden in July: first, that in view of the existing statutory role of the Local Government and Social Care Ombudsman in considering complaints against council enforcement, the ECB would not routinely hear such complaints itself (although it would retain general oversight of council enforcement services); secondly, as a result of the reduced costs of the ECB not routinely taking complaints, we would offer councils a reduced 0.3% levy. In addition, we are proposing that early adopter councils need only pay their levy from April 2025 (to cover 2025-26) but can attain public accreditation from December 2024 alongside firms.

Communications and Engagement

  1. The team are currently preparing communications campaigns for the launch of the publication of the standards and BWV research, the complaints consultation and year two of the accreditation scheme.

  2. They have also been meeting with relevant stakeholder organisations to discuss the use of ‘back links’ to increase traffic to the ECBs website and as such, improving our SEO optimisation which will increase our visibility amongst new audiences.

  3. In addition to what has already been noted above, wider engagement over the last month has included:
    • Speaking at IRRV regional events in Norwich and Leeds
    • Speaking at a session with the Money Advice Group (Yorkshire and North Lincs)
    • Attending a CIVEA workshop for small firms to help them prepare for operational oversight from the ECB

Political strategy and public affairs

  1. The Board has a separate paper on the organisation’s response to Joe Shalam’s draft political engagement strategy.

  2. We have not received confirmation yet, but we continue to press for the new Minister for the Courts at MoJ, Heidi Alexander, to meet the Chair and CEO in October to discuss the case for giving the ECB some limited statutory powers.

Upcoming engagement

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

• Meeting with members of Marston’s Independent Advisory Group to discuss ECB standards and complaints handling


• Speaking at the Civil Court Users Association Annual Conference.

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