Catherine Brown, Chair, Enforcement Conduct Board
We are currently working on our first full business plan, which will set out our priorities for the year ahead and beyond. Through everything we do, we are guided by our five key principles of independence, ambition, proportionality, collaboration and transparency. Transparency is part of the reason for writing this regular update, so that all stakeholders can be aware of what the ECB is doing and our intentions. A further transparent step will be to consult on and then publish the business plan.
This week, as part of that consultation, I’m pleased that we held the first meeting of our engagement group, involving representatives from the trade association CIVEA, the High Court Enforcement Officers Association, enforcement businesses and the debt advice sector. This reflects our principle of collaboration. Our engagement group is just one of the ways we will seek to work with people. We are putting other communication routes in place, so interested parties can interact with us and contribute to what we are trying to achieve.
We have been clear from the outset that the success of the Enforcement Conduct Board and the subsequent benefits it can bring to those experiencing enforcement and others will only happen by everyone working together. It is through the collaborative steps we have taken so far that we are now able to share our early proposed priorities.
There are five key areas of focus: data collection, reviewing complaints processes, consulting on a code of practice, establishing wide coverage of our oversight, and building our effectiveness and engagement.
To ensure proportionality in our work, we need to gather the data on exactly what is happening to those experiencing enforcement and understand the prevalence or otherwise of consumer detriment. Therefore, we will build a transparent evidence-base drawing on information from the enforcement and debt advice sectors. We will convene a series of workshops with stakeholders to identify the reporting requirements and explore research opportunities using existing data. This will be the platform on which we can take further proportionate action.
Our second area of work is to review the current processes for complaints. As well as making sure that the complaints process works well and fairly we want to learn from what complaints can tell us about how the system is working and where improvements to processes might deliver benefits to people experiencing enforcement and to businesses alike. Our aim is to provide guidance about how a robust, fair, and accessible complaints system ought to operate. We also want to produce a costed plan to take over responsibility for the final, independent stage of non-ombudsman complaints. These ambitions are
important steps towards delivering on our mission to ensure everyone experiencing enforcement is treated fairly.
This relates to our third strand of work, which is to consult widely on the development and implementation of updated standards and a code of practice. An important part of that will be developing rules on how to identify and deal with vulnerability and affordability. We intend to collaborate with the industry, debt advice sector and government to plan the review in the first half of 2023/4, with the aim of starting the standards review in the second half of the year. Underpinning all this work will be the continuation of our efforts to widen our coverage, so that no enforcement agency, whether privately owned or in-house, can avoid the rules. This will require local authorities, Government departments and other responsible creditors to commit to only working with enforcement agents who are signed-up to high standards. To enable this, we will develop a straightforward accreditation scheme so that creditors are fully aware of those enforcement businesses that are committed to being under independent oversight.
Finally, we will continue to establish the ECB as a cost-effective, impactful, collaborative and credible oversight body. In order to fulfil our ambitions, we recognise we will need to draw on technical advice and expertise on how the industry works and on its impacts. Effective stakeholder engagement will also be fundamental to achieving this goal and that is why we will continue to publish these updates and provide opportunities for consultation and feedback. Throughout all our work, our independence is vital. This is key to securing the trust and confidence of the industry, especially those working as enforcement agents, the debt advice sector, government and the public.
We will publish the draft business plan in the next week or so, and I would welcome thoughts from all stakeholders on the proposed priorities we’ve set out above or on the full plan when it appears – you can email contact@enforcementconductboard.org. To stay up to date on developments, please do sign up to our mailing list below.