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Our original report response was ~~~~~Beagles formal response to OFT PCA Market Study Consultation Nov 2008~~~~~~ - Legal Beagles - there are links there to the OFT's follow up report as well.
We are currently working on updating the report to take into account the vast amount of work and changes that have occured over the past year - BCOBS, better guidance, Post Offices, changes to charging structures and so on, and would appreciate any opinions or comments or critcisms on how the PCA Market has improved since November 2008.
We are delighted to have been asked to do this, and pleased all our members have the opportunity to be involved in a small way in shaping the future of the personal current account market in the UK.
6.4 The OFT will enter into intensive discussions with banks, consumer
groups and other organisations early in January with the intention of
seeking rapid change. In particular, it will look to secure changes in the
areas identified in paragraph 4.9 of this document, concerning control,
clarity and predictability, and responsibility. A number of options may be
available to secure these objectives, ranging from voluntary action
(which could be supported by amendments to the Lending Code46 and
guidance issued by the OFT, for example) to legislative change. It will
report on progress by the end of March 2010.
Supporting change in the market
4.9 In relation to the OFT's objective of achieving market change, the OFT
will, in particular, be seeking improvements around unarranged
overdrafts in three critical areas:
• Control. Consumers need greater ability to manage their finances,
both for their own interests and to ensure that competition operates
more effectively in the PCA market. At a minimum, the OFT believes
that consumers must have a real choice about whether to have a
facility that allows them to go into unarranged overdraft or not.
• Clarity and predictability of charging for unarranged overdrafts.
Current charging structures are typically not simple to understand
and predict. It has also become clearer through the OFT's recent
work on high-cost credit36 that consumers find it difficult to compare
the costs of using unarranged overdrafts with other forms of shortterm
credit. The OFT will be considering whether there is a simple
method of describing the charges for unarranged borrowing that
allows these comparisons to be made more effectively and for
competition to work better.
• Responsibility. All banks have a duty not to lend irresponsibly37, and
the OFT can have particular regard to this in administering the
licensing regime under the Consumer Credit Act 1974, including
assessing fitness to hold a credit licence38 or deciding whether to
impose requirements on individual traders39. The OFT will consider as
part of this process what expectations are appropriate for lending
through unarranged overdrafts, especially to customers for whom
other lending arrangements might be more appropriate40.
4.10 The OFT will discuss these issues intensively with banks, consumer
groups and other organisations over the next few weeks, with the aim of
reaching a voluntary agreement from the banks to implement the
changes sought. The Banks have indicated to the OFT that they are
willing to enter into such discussions41. The OFT expects to issue a
report on progress in the first quarter of 2010. The OFT will also report
back at that stage on the case for further actions, such as the need for
legislative change.
4.11 This work will be taken forward under the wider PCA market study and
will take place whether an investigation under the UTCCRs continues or
not. In seeking to change the market going forward, the OFT's view is
that continuing an investigation under the UTCCRs along the lines of any
or all of the options that appear to be available is unlikely to provide
additional benefit for this work, given changes already made and the
prospect of further changes arising from future developments.
Compiling a list of changes in the PCA Market since 2008 - all help appreciated and will add things to this post in brief.
Main one - http://www.oft.gov.uk/shared_oft/per...rges-Order.pdf
IMPLEMENTED PHYSICAL CHANGES
(need to list main points and effects)
Banking Code gone replaced with Regulated BCOBS
Banking Conduct of Business Sourcebook
Lending Code introduced
http://www.lendingstandardsboard.org...endingcode.pdf
Changes to Charging Structures/Levels - list banks and changes with supporting T&C's
BARCLAYS
RBS
HBOS
LLOYDS
Banks Terms and Conditions and Standard Contracts - Legal Beagles
new a/cs
ABBEY ZERO
LLOYDS CONTROL
REPORTS, STUDYS, CONSULTATIONS
OFT follow up report on PCA market study
The Office of Fair Trading: Market study into personal current accounts
OFT consultations
- The Office of Fair Trading: OFT announces review of debt management practices
- The Office of Fair Trading: Banks agree to make improvements to personal current account market in the UK
- The Office of Fair Trading: OFT consults on irresponsible lending guidance
-
Government
- Financial Services Bill
- Consumer White Paper - BIS
MERGERS / SPLITS etc
Cheshire Building Society merges with Nationwide Building Society—December 2008*
Derbyshire Building Society merges with Nationwide Building Society November 2008
Catholic Building Society merges with Chelsea Buidling Society December 2008
Barnsley Building Society merges with Yorkshire Building Society December 2008
Scarborough Building Society merges with Skipton Building Society March 2009
Britannia Building Society merges with Co-Operative Bank July 2009
(thanks Nattie)
OTHER STUFF
Post Office Bank ? BBC News - Post Office bank plans outlined by government
Renewal of POCA (yeyy)
Tesco Bank ?
Credit Unions ?
We are currently working on updating the report to take into account the vast amount of work and changes that have occured over the past year - BCOBS, better guidance, Post Offices, changes to charging structures and so on, and would appreciate any opinions or comments or critcisms on how the PCA Market has improved since November 2008.
We are delighted to have been asked to do this, and pleased all our members have the opportunity to be involved in a small way in shaping the future of the personal current account market in the UK.
6.4 The OFT will enter into intensive discussions with banks, consumer
groups and other organisations early in January with the intention of
seeking rapid change. In particular, it will look to secure changes in the
areas identified in paragraph 4.9 of this document, concerning control,
clarity and predictability, and responsibility. A number of options may be
available to secure these objectives, ranging from voluntary action
(which could be supported by amendments to the Lending Code46 and
guidance issued by the OFT, for example) to legislative change. It will
report on progress by the end of March 2010.
Supporting change in the market
4.9 In relation to the OFT's objective of achieving market change, the OFT
will, in particular, be seeking improvements around unarranged
overdrafts in three critical areas:
• Control. Consumers need greater ability to manage their finances,
both for their own interests and to ensure that competition operates
more effectively in the PCA market. At a minimum, the OFT believes
that consumers must have a real choice about whether to have a
facility that allows them to go into unarranged overdraft or not.
• Clarity and predictability of charging for unarranged overdrafts.
Current charging structures are typically not simple to understand
and predict. It has also become clearer through the OFT's recent
work on high-cost credit36 that consumers find it difficult to compare
the costs of using unarranged overdrafts with other forms of shortterm
credit. The OFT will be considering whether there is a simple
method of describing the charges for unarranged borrowing that
allows these comparisons to be made more effectively and for
competition to work better.
• Responsibility. All banks have a duty not to lend irresponsibly37, and
the OFT can have particular regard to this in administering the
licensing regime under the Consumer Credit Act 1974, including
assessing fitness to hold a credit licence38 or deciding whether to
impose requirements on individual traders39. The OFT will consider as
part of this process what expectations are appropriate for lending
through unarranged overdrafts, especially to customers for whom
other lending arrangements might be more appropriate40.
4.10 The OFT will discuss these issues intensively with banks, consumer
groups and other organisations over the next few weeks, with the aim of
reaching a voluntary agreement from the banks to implement the
changes sought. The Banks have indicated to the OFT that they are
willing to enter into such discussions41. The OFT expects to issue a
report on progress in the first quarter of 2010. The OFT will also report
back at that stage on the case for further actions, such as the need for
legislative change.
4.11 This work will be taken forward under the wider PCA market study and
will take place whether an investigation under the UTCCRs continues or
not. In seeking to change the market going forward, the OFT's view is
that continuing an investigation under the UTCCRs along the lines of any
or all of the options that appear to be available is unlikely to provide
additional benefit for this work, given changes already made and the
prospect of further changes arising from future developments.
Compiling a list of changes in the PCA Market since 2008 - all help appreciated and will add things to this post in brief.
Main one - http://www.oft.gov.uk/shared_oft/per...rges-Order.pdf
IMPLEMENTED PHYSICAL CHANGES
(need to list main points and effects)
Banking Code gone replaced with Regulated BCOBS
Banking Conduct of Business Sourcebook
Lending Code introduced
http://www.lendingstandardsboard.org...endingcode.pdf
Changes to Charging Structures/Levels - list banks and changes with supporting T&C's
BARCLAYS
RBS
HBOS
LLOYDS
Banks Terms and Conditions and Standard Contracts - Legal Beagles
new a/cs
ABBEY ZERO
LLOYDS CONTROL
REPORTS, STUDYS, CONSULTATIONS
OFT follow up report on PCA market study
The Office of Fair Trading: Market study into personal current accounts
OFT consultations
- The Office of Fair Trading: OFT announces review of debt management practices
- The Office of Fair Trading: Banks agree to make improvements to personal current account market in the UK
- The Office of Fair Trading: OFT consults on irresponsible lending guidance
-
Government
- Financial Services Bill
- Consumer White Paper - BIS
MERGERS / SPLITS etc
Cheshire Building Society merges with Nationwide Building Society—December 2008*
Derbyshire Building Society merges with Nationwide Building Society November 2008
Catholic Building Society merges with Chelsea Buidling Society December 2008
Barnsley Building Society merges with Yorkshire Building Society December 2008
Scarborough Building Society merges with Skipton Building Society March 2009
Britannia Building Society merges with Co-Operative Bank July 2009
(thanks Nattie)
OTHER STUFF
Post Office Bank ? BBC News - Post Office bank plans outlined by government
Renewal of POCA (yeyy)
Tesco Bank ?
Credit Unions ?
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