Module 1: Introduction to FCA Arrears, Default, and Recovery Rules

• Overview of FCA regulations (CONC 7)
• Key obligations under Principle 12 (Consumer Duty) and Principle 6 (Customers' Interests)
• Application of rules to different firm types, including transitional provisions for Gibraltar-based firms

Module 2: Creating Clear Arrears Policies and Procedures

• CONC 7.2: Establishing clear, effective policies for managing customers in arrears or default
• Handling vulnerable customers: Mental health and capacity limitations
• Importance of fair treatment: FCA's guidance for the fair treatment of vulnerable customers (FG21/1)

Module 3: Treatment of Customers in Arrears or Default

• CONC 7.3: Requirements for treating customers in arrears or default fairly
• Forbearance measures: Reduction or waiver of interest/charges, token payments, alternative repayment arrangements, refinancing
• Developing sustainable repayment arrangements and income assessments

Module 4: Effective Communication and Customer Support

• CONC 7.3.13A: Timely, clear communication to customers in arrears or default
• Providing free and impartial debt advice and engaging with customers through appropriate channels
• Transparency in income and expenditure assessments

Module 5: Repossessions – Guidelines and Procedures

• CONC 7.3.17: Repossession as a last resort; steps to take before repossession
• Ensuring compliance with forbearance agreements before considering repossession
• Informing customers about their rights under the Consumer Credit Act (sections 99 and 100)

Module 6: Continuous Payment Authority and Enforcement of Debts

• CONC 7.6: Appropriate use of continuous payment authority (CPA) in debt recovery
• Rules for applying interest and charges, especially for customers in arrears
• Ensuring enforcement actions comply with the FCA guidelines for treating vulnerable customers fairly

Module 7: Compliance and Regular Reviews

• Conducting compliance reviews of arrears and recovery policies
• Identifying and resolving areas where policies or actions may not meet FCA standards
• Adapting to changes in customers' circumstances to ensure continued fair treatment

Module 8: Case Studies and Practical Exercises

• Real-world scenarios: How to apply FCA guidance in different situations
• Group exercises on developing appropriate policies for arrears management and customer support

Thank You!

Any Questions?