Chief Executive’s Report, September 2024


Introduction

  1. Since the Board last met we have launched our consultation on the ECB standards and it has been really encouraging to see the early response to this from stakeholders. The consultation has been shared widely by others on social media and we have already had a number of constructive discussions with those who have started to work through it.

  2. Launching the consultation was a big milestone for the ECB. We got here thanks to the team’s excellent work and also the extensive engagement and support that we have received from stakeholders across the sector. We are doing significant outreach during the consultation period and are also preparing to analyse responses and keep things moving once the consultation closes.

  3. That said, with the consultation out, we have also been able to devote more attention to other key ECB priorities, such as development of our complaints process, future plans for the data returns and accreditation of in house teams at Local Authorities.

Current cash position and finance management

  1. The cash position at the 23 August was approximately £860k against a predicted balance of £954k. This variance is largely due to a staged payment arrangement being agreed with one of the largest firms. Taking account of this, the cash position remains where we expect it to be and there are no concerns.

  2. We have been discussing changing the ECB’s banking arrangements recently as while Co-Op has been an acceptable service with few noteworthy issues, there are a number of functionalities and quirks of the system that, as the ECB grows, are becoming increasingly burdensome to work around. We have researched three options and of these, Lloyds banks has emerged as the closest to the ECB’s requirements. We will utilise the ‘Safe Switch Guarantee’ to ensure a smooth transition to the new bank in time for the second round of levy collection.

Recruitment

  1. We currently have three new roles coming up over the next year: Administrative Officer, Complaints Investigator and a Supervision Manager.

  2. There has been a lot of interest in the Administrative Officer role. We have a shortlist meeting scheduled for 9 September with interviews scheduled for 19 September.

  3. We are also in the process of recruiting a complaints investigator with interviews scheduled for 5 September.

Accreditation and the levy

  1. In June we issued levy requests to the eight largest enforcement firms by turnover and have received payment from all eight, with one agreeing a staged payment plan.

  2. Requests to all remaining accredited firms will go out in Autumn this year.

Research and evidence

  1. We have received the interim report from our research partner, M.E.L on the BWV research project. The Board were taken through the early emerging findings at their meeting on 18 July. We are now discussing the most recent findings from the research with M.E.L, as well the proposed structure and format of the final report, which the ECB expects to receive at the end of September. The full report will be presented at the Board meeting on 9 October.

ECB Standards Development

  1. The standards consultation launched at the end of July and will close on 13 September. To date we have had two consultation responses but expect to receive many more over the next two weeks.

  2. We have also been carrying out in-person workshops with debt advisors, one with rooted finance in August and with Citizens Advice in the next couple of weeks. In addition to this we have run deep dive sessions on the standards with some experts in the enforcement sector to ensure that the detail of the standards has been thoroughly scrutinised in advance of final publication.

Complaints handling

  1. As set out in the complaints paper that Board is reviewing in this meeting, we are focusing efforts on getting a number of policy documents ready to consult on in early October. We have also had productive meetings with the Energy Ombudsman, Communications Ombudsman, FOS and PHSO, all of whom have supported our proposed working model for complaints.

Creditor engagement

  1. Along with the standards consultation, in July the ECB began to discuss with councils across England and Wales its proposal to invite accreditation of council in-house enforcement teams for the first time when the ECB’s accreditation window opens in November.

  2. The ECB’s accreditation offer to local authorities features clarification on two key points, agreed by the Board: 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 reduction on their levy for accreditation, to the effect that a charge amounting to 0.3% of their annual turnover from enforcement fees would be required for this year, around one- third lower than the levy for private sector firms.

  1. The Director of Creditors and Government (DCG) has directly contacted a number of local authorities known to be interested in seeking accreditation for their in-house teams. The Institute of Revenues, Rating and Valuation (IRRV) has featured details of both the in-house accreditation proposal and the standards consultation in its latest newsletter, which the IRRV estimates goes out to over 6000 customers, including all 333 local authorities in England and Wales. The DCG will be following up interest in August and September.

Communications and Engagement

  1. The team are proactively planning a suite of communications products for the publication of the ECB Standards and launch of our complaints scheme, including the development of an accessible standards document.

  2. They have also recently completed part of the website project, which included search engine optimisation, and the creation of a Welsh language version. The Board agreed at its last meeting that the ECB would remain on X for now but keep this position under review. In the light of events over the summer, we believe the arguments for moving away from X have become stronger. We are now focussing on developing alternatives to X that would limit any downsides from coming off the platform in terms of engagement with members of the public, with journalists and with politicians. For now we are continuing to use X, as are most other public bodies.

  3. The team have also spent some time scoping a potential Brand/Website refresh project.

Political strategy and public affairs

  1. We have now received the first draft of the Political Engagement Strategy that was developed by Joe Shalam to help the ECB position itself for productive working with the new administration. Joe will be leading a session with the Board to present his findings in the meeting.

  2. We anticipate that the new Minister for the Courts, Heidi Alexander, will wish to meet the Chair and CEO in October.

Upcoming engagement

  1. Over the coming month, the team have the following engagements planned:
  • A range of engagements across the country by the DCG with local authorities on the issues of accreditation and standards

  • Attending a CIVEA workshop for small firms, aimed at helping them prepare for the start of ECB supervision

  • Speaking at the IRRV East Anglia forum meeting in Norwich

  • Speaking to various regional Money Advice Group forums about the ECB’s standards and work

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

  • Meeting with the Public Services Ombudsman for Wales

  • Session on the standards with CAB debt advisors
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