This was our last Board meeting of the financial year and so a good opportunity for the Board to reflect on how much progress has been made since this time last year, when we were still in the early stages of developing our standards and complaints process!
But the main focus of the meeting was forward looking, and the first item on our agenda was an analysis of responses to the consultation on our draft Business Plan and draft budget. This is now the third time that we have consulted on our business plans and we reflected on improvements in our processes each year so far.
As ever, we are very grateful for the input that we have received from our stakeholders, which enabled the Board to have a productive discussion on what changes to make before finalising our business plan and budget.
Overall, responses were supportive of the focus on delivery and on the main work within the plan. Within this, some responses expressed caution about our plans to produce a “know your rights” document and concern that the ECB was planning to devote significant resources to public awareness type campaigns. The Board had discussed this already in January and agreed that the ECB’s focus for this work should be on ensuring that those who experience enforcement action have access to user friendly material on the process and their rights. We do not believe that the ECB should be undertaking a far reaching general public awareness campaign and will make this clear in the final business plan.
This work is also intended to be consistent with responses to the standards consultation that the ECB should produce independent, user friendly information for people experiencing enforcement to help them understand the enforcement process and their rights within it.
In relation to the budget, we discussed the financial context and feedback from industry on the impact of this on their operations. We also noted that stakeholders were largely supportive of the workplan and, in spite of the financial context, there was limited opposition to the ECB’s overall budget.
Most of the specific challenges on the budget were focussed on the money assigned to the lived experience user testing work. And this was often linked to the concerns about the ECB spending disproportionately on the “know your rights” work. We discussed this with the team and confirmed that the majority of the budgeted spend for lived experience workshops is assigned to development of the vulnerability and ability to pay standards – the budget assigned to the “know your rights” is a much smaller part of this budget. We will seek to provide further context in the final business plan on this. There was also scrutiny of some specific budget lines which we discussed and will provide further context to in the consultation response.
Based on the responses and our discussion, we agreed that, subject to updated numbers and checks with the accountants, the final budget will be approximately £1.4m. The Board was pleased to hear that, having now received turnover figures from industry and from the new in-house teams that we accredit, we will be able to meet this budget with a lower % levy than indicated in the consultation paper. We will confirm the exact amount when we publish the final business plan and consultation response in the next two weeks.
The other main item on the agenda was an initial scoping discussion on developing new standards on vulnerability and ability to pay.
One thing that we know will be central to getting these standards right is hearing from a wide range of stakeholders. To this end, we agreed an engagement plan based on the approach we took to development of our standards last year. This will mean significant engagement with stakeholders in meetings and workshops through the spring, to inform a public consultation over the summer.
We had a high-level discussion about the overall approach to each of these areas, based on a “define, identify, respond” model. We also discussed the fact that creditors have a large role to play in both areas and how important it will be to ensure that they are engaged and involved in development. And we discussed the importance of making the overall process of enforcement safe for the wide range of people who experience it.
The next step will be for the ECB to draft a discussion document, which will form the basis of the targeted engagement and workshops from April.
Alongside these main papers, the Board received an update on the operation of our complaints scheme. We are starting to see increasing numbers of people reaching us after they have received a final response from the firm and it is very encouraging to know that the scheme is already starting to make a difference for real people. The Board is looking forward to seeing the evidence that comes from this in the future, as the volume increases further. The next opportunity will be April, when the Board next meets in London!
Catherine Brown
Cadeirydd, Bwrdd Ymddygiad Gorfodi