Chris Nichols, CEO, Enforcement Conduct Board
This has been another action-packed month as we work through the details of how our accreditation scheme will operate when it launches this summer, whilst continuing to engage, listen and learn through a wide range of forums across England and Wales.
Countdown to launch
The launch of our accreditation scheme will be a big milestone in getting ECB oversight going in practice. By asking enforcement firms to become accredited, we will be seeking an active commitment to our oversight and to pursuing high standards. And it is through our accreditation framework that we will exercise our oversight in practice, to create meaningful accountability.
We published the five criteria for accreditation in our business plan and our focus has since turned to creating the formal framework to bring these to life. This will be discussed at our forthcoming Board meeting in Cardiff at the end of the month and we are hoping to be able to open the window for applications to be accredited in September. I will share further details in my next blog, after the July Board meeting.
We have also developed an “ECB accredited” logo that accredited firms will be able to use, under licence, to let the world know that they are accredited by the ECB.
Joining the dots
Outside of accreditation, we have spent a lot of time this month out and about, engaging with stakeholders about our workplans and continuing to learn about the important work being done across this space. The more we do this, the more we are starting to join the dots between issues raised by different groups, and how these relate back to our mission to ensure that everyone experiencing enforcement action is treated fairly.
For example, earlier this month we visited Money Advice Trust in Birmingham to see first-hand the important work they do supporting individuals and businesses with tackling debt. During this visit, we spent some time with debt advisors at both National Debtline and Business Debtline listening to calls and getting their views on the impact of enforcement. We heard similar themes to those raised when I visited Stepchange last month, such as concerns about some Enforcement Agents misrepresenting their powers on the doorstep. It is not just the advice sector that has raised this issue with me and it is a concern that we take seriously. We will use our forthcoming research into doorstep practices to establish how often misrepresentation is arising and how it manifests, to help inform what interventions we can put in place to address it.
We have also continued our introductory visits with enforcement firms, including spending time with welfare teams at two different firms, looking at how they approach vulnerability. I was particularly drawn to efforts to break down the high-level concept of vulnerability into specific categories, recognising that different types of vulnerability require different responses. This is something I am keen that we explore further when we come to look at how vulnerability should be addressed in our own standards and code of practice.
I also spoke at a number of events, including the Local Authority Civil Enforcement Forum (LACEF), the Enforcement Law Review Group and Welsh Revenues and Benefits Managers Group. At all of these events, I fielded some very thoughtful questions and I was struck by the quality of the discussion that followed my presentations. This is exactly why I am always at pains to emphasise how important it is to me that we hear a wide range of views as we develop our approach to oversight. Discussion at these events has helped to underline the importance of engaging creditors in the ECB’s mission, as well as ensuring that our accreditation framework will accommodate in house enforcement teams at Local Authorities.
Funding the ECB
This week we will be issuing requests for levy payments from the eight largest firms, on the terms set out in our business plan. We will be requesting payment from all other firms from October.
A small but perfectly formed team
Finally, I’m happy to announce that we have now finalised recruitment of our core team for this year, which comprises a Policy Manager (Alice Kelly), Head of Governance and Operations (Jenny Prior) and Director of Creditors and Government (David Parkin – who has joined us on secondment from the Ministry of Justice for a year). We will also be joined in the Autumn by our new Director of Policy and Oversight, and I look forward to sharing the details of who we have appointed shortly.
I am very pleased to have reached this position so that we can turn our attention fully to delivering the many important strands of work in our business plan, starting with accreditation!
Until next time.