We were in Wales again for our last Board, this time in sunny North Wales. This provided another fruitful opportunity to engage with Welsh creditors, who have been at the forefront of supporting the ECB’s mission. This time, we had a workshop with a group of enforcement leads from North Wales councils, some of whom were involved in the Welsh Local Government Association’s decision to commit to Welsh Local Authorities only using ECB accredited providers.
It was very useful and interesting to hear about the particular revenue challenges facing Local Authorities in the area and what is being done to encourage fair, respectful and effective enforcement. It was also very welcome to hear a real appetite for ECB accreditation to be extended to in-house teams, of which there are quite a few across Wales. We plan to open up accreditation to this group in the coming months.
In the wider Board meeting, the main item on the agenda was our forthcoming consultation on our Standards. The Board received a report on the extensive engagement that the team has done since our last meeting and the development of its thinking on the standards as a result of this. It was very heartening to hear that so many voices from across the sector have taken part in this targeted engagement and the feedback we have received has been constructive and supportive of the overall direction of travel.
The Board tested the team’s thinking and agreed the overall positions that we should take on key issues as a basis for consultation, including modes of entry, dealing with third parties and monitoring and audit. The consultation will be launched next week and we look forward to further constructive engagement from across the sector on the draft standards.
We also discussed the ECB’s approach to complaints handling. This will be one of our core functions in driving fair enforcement, both through ensuring effective redress for members of the public, as well as identifying useful learning to improve services across the enforcement industry. Overall, it is essential that the ECB is able to determine complaints about potential breaches of its own standards and directly hold accredited firms to account if breaches are found.
The current complaints landscape is very fragmented and confusing and we are clear that the ECB entering this space must be a net benefit to people with a complaint. . Without altering peoples’ rights to complain to separate statutory ombudsmen services, we will offer a targeted and simplified route to complain to the ECB about the behaviour of enforcement firms and enforcement agents. We are looking forward to further engagement with the Local Government and Social Care Ombudsman, the Public Services Ombudsman for Wales and others, on how we can work collaboratively towards a streamlined interface for members of the public whose complaints might span both enforcement and creditor behaviour.
We then moved on to discuss the ECB’s offer for the accreditation of in-house enforcement teams at Local Authorities later this year. We agreed that the overall accreditation framework should be the same for this group as for private firms, with two key changes. Firstly, the ECB will not handle complaints against in-house enforcement firms, as these providers are already directly accountable to statutory ombudsmen schemes in a way that does not exist for contracted-out enforcement work. Secondly, as we would not be handling complaints, we felt that this would justify offering a reduced ECB levy to in-house teams. Our current thinking is to offer a reduction of around 1/3 on the 0.44% of annual enforcement fee turnover current levied on the private enforcement industry. We are confident that these proportionate changes will enable a significant cohort of inhouse teams to come under ECB accreditation.
And finally, we did some thinking as a Board about the implications of a change of Government and the opportunities and risks that this presents to the ECB and its mission. We are looking forward to building good working partnerships with the new ministerial teams at the Ministry of Justice and the Ministry of Housing, Communities and Local Government in particular.
Catherine Brown, Chair