Concerns raised 19 Failure to assess new drivers’ understanding of passenger effects on braking, stability and handling View source Failure of licensing arrangements to address combined inexperience, peer presence and full vehicle loading View source Lack of a coordinated cross-sector approach to early indications of unsafe behaviour View source Unequal behavioural oversight of named drivers with similar early-stage risk profiles View source Failure of the standard driving test to require experience on challenging rural roads View source Inconsistent incorporation of safety considerations into young-driver insurance products View source Unclear detection and review of dangerous-driving content uploaded by minors View source Lack of safeguarding processes to identify repeated unsafe conduct among young users View source Uncertainty about wider algorithmic dissemination of dangerous-driving content View source Lack of a consistent method to identify concealed higher-than-expected use by young named drivers View source Insufficient understanding of peer influence, vehicle loading and rural road hazards View source Unclear insurer processes for collecting, interpreting and acting on telematics data View source Difficulty identifying true vehicle use by young named drivers View source Peer sharing of high-risk driving normalising and reinforcing risk-taking View source Failure of test requirements to assess passenger and load-related vehicle dynamics View source Unclear communication of telematics use and safety implications to young drivers and families View source Failure of qualification competencies to cover early independent-driving conditions View source Failure of licensing arrangements to provide structured progression aligned to early post-test risk View source Lack of a uniform approach to applying telematics View source See 16 more concerns
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
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AI-generated summary
Harry Joseph Purcell and Matilda (Tilly) Grace Seccombe · Prevention of Future Deaths report
This summary was generated using AI from the published report. Please read the original report for the complete account.
Report summary
Harry Joseph Purcell and Matilda (Tilly) Grace Seccombe sustained fatal injuries in a single-vehicle collision on 21 April 2023, when a recently qualified 17-year-old driver travelled at excessive speed on a rural road and lost control. The report raised concerns about the combined risks of driver inexperience, peer passengers, vehicle loading and rural-road conditions, as well as issues concerning driver licensing, insurance oversight, unsafe-driving content shared on Snapchat and the lack of coordinated responses to unsafe behaviour.
Read the report on judiciary.uk
× Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure to assess new drivers’ understanding of passenger effects on braking, stability and handling
Wider context from the report “2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling . The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of licensing arrangements to address combined inexperience, peer presence and full vehicle loading
Wider context from the report “1. The inquest noted that newly qualified drivers may carry multiple peer-age passengers immediately after passing their test. This case suggests that inexperience, peer presence and full vehicle loading can combine to elevate risk , and it is unclear how current licensing arrangements address these combined factors .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Lack of a coordinated cross-sector approach to early indications of unsafe behaviour
Wider context from the report “10. There does not appear to be a coordinated approach linking driver training bodies, insurers, social media platforms and road-safety organisations in identifying or responding to early indications of unsafe behaviour among newly qualified drivers .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Unequal behavioural oversight of named drivers with similar early-stage risk profiles
Wider context from the report “4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers. Named drivers may not be subject to telematics monitoring , which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of the standard driving test to require experience on challenging rural roads
Wider context from the report “2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip . Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Inconsistent incorporation of safety considerations into young-driver insurance products
Wider context from the report “5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data, or how consistently safety considerations are incorporated into insurance products designed for young drivers .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Unclear detection and review of dangerous-driving content uploaded by minors
Wider context from the report “7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors . It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Lack of safeguarding processes to identify repeated unsafe conduct among young users
Wider context from the report “8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour. There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Uncertainty about wider algorithmic dissemination of dangerous-driving content
Wider context from the report “7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors. It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Lack of a consistent method to identify concealed higher-than-expected use by young named drivers
Wider context from the report “6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Insufficient understanding of peer influence, vehicle loading and rural road hazards
Wider context from the report “9. The circumstances of this case highlight the continued significance of peer influence, vehicle loading and rural road hazards for young drivers. It is unclear how well these risks are understood by young people, parents (particularly those organising insurance cover), or schools .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Unclear insurer processes for collecting, interpreting and acting on telematics data
Wider context from the report “5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data , or how consistently safety considerations are incorporated into insurance products designed for young drivers.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Difficulty identifying true vehicle use by young named drivers
Wider context from the report “4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers . Named drivers may not be subject to telematics monitoring, which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Peer sharing of high-risk driving normalising and reinforcing risk-taking
Wider context from the report “8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour . There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of test requirements to assess passenger and load-related vehicle dynamics
Wider context from the report “3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling. Test requirements do not involve passengers or load-related vehicle dynamics , raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Unclear communication of telematics use and safety implications to young drivers and families
Wider context from the report “6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers . The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families , which may influence decisions made when arranging insurance.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of qualification competencies to cover early independent-driving conditions
Wider context from the report “3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling . Test requirements do not involve passengers or load-related vehicle dynamics, raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of licensing arrangements to provide structured progression aligned to early post-test risk
Wider context from the report “2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Lack of a uniform approach to applying telematics
Wider context from the report “6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance.
” Open source report
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Encourage effective and appropriate use of telematics data in the insurance sector.
Verbatim wording from the response “We have carefully considered the matters raised in your report. While we cannot act beyond our statutory remit, we remain committed to ensuring that firms meet the highest standards under our existing rules. We continue to encourage effective and appropriate use of telematics data in the insurance sector.”
Source location Response from Financial Conduct Authority Page 3 · response Published 18 December 2025
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Government, through primary legislation, is responsible for decisions about requiring specific insurance product features or telematics.
Verbatim wording from the response “As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.”
Source location Response from Financial Conduct Authority Page 1 · response Published 18 December 2025
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Mandatory telematics and driver or road safety matters fall outside the regulator’s remit.
Verbatim wording from the response “As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.”
Source location Response from Financial Conduct Authority Page 1 · response Published 18 December 2025
Open published response
17 Dec 2024 Susan Marie Karakoc · Prevention of Future Deaths report Nottinghamshire
View report summary
Concerns raised 3 Search engines readily returning websites selling potentially fatal prescription medications View source Failure of prescription medication supply-chain legitimacy monitoring to prevent ready online supply View source Failure of systems to detect criminal medication supply enterprises and alert relevant authorities View source
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
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AI-generated summary
Susan Marie Karakoc · Prevention of Future Deaths report
This summary was generated using AI from the published report. Please read the original report for the complete account.
Report summary
Susan Marie Karakoc collapsed at home on 1 December 2023 and died in hospital the following day after suffering a hypoxic brain injury. The report states that she obtained prescription medications from online sources selling medicines off-label, and that toxicological examination identified toxicity associated with the chain of events leading to her death. Concerns included the ready availability of such websites through search engines, inadequate monitoring of online medication supply chains, and ineffective detection of financial services supporting criminal enterprises.
Read the report on judiciary.uk
× Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Search engines readily returning websites selling potentially fatal prescription medications
Wider context from the report “1. There is evidence of search engines readily returning websites which sell prescription medications , including those that sell highly addictive sleeping tablets and painkillers which can and do cause fatalities . I am concerned how readily search engines return websites such as these ;
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of prescription medication supply-chain legitimacy monitoring to prevent ready online supply
Wider context from the report “2. I am concerned that the current system for monitoring the legitimacy of supply chains for medications available in England and Wales via prescription is not preventing the ready supply of such medications online ;
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Failure of systems to detect criminal medication supply enterprises and alert relevant authorities
Wider context from the report “3. There is evidence that banks form a legitimate part of the supply chain, and that this is crucial to the functioning of these criminal enterprises. I am concerned that the current system for detecting such criminal enterprises and alerting the relevant authorities is not effective .
” Open source report
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Absent relevant intelligence, firms may be practically unable to identify and prevent payments to particular merchants.
Verbatim wording from the response “Firms use merchant details to understand where customer payments are being made to, and firms use these to prevent transactions where they identify suspicious activity or fraud. Suspicious activity can be identified by firms through receipt of intelligence, including from law enforcement, through receipt of serious complaints, unusual frequency and values of payments, and other similar sources. Absent of such intelligence, it would be practically difficult for a firm to identify and prevent payments to a particular merchant.”
Source location Response from FCA Page 2 · response Published 27 December 2024
Open published response
9 Apr 2018 Naseeb Singh Chuhan · Prevention of Future Deaths report West Yorkshire Eastern
View report summary
Concerns raised 2 Inadequate financial checks View source Encouragement of loan dependence despite awareness of borrower dependence View source
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
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AI-generated summary
Naseeb Singh Chuhan · Prevention of Future Deaths report
This summary was generated using AI from the published report. Please read the original report for the complete account.
Report summary
Naseeb Singh Chuhan was a first-year student at Leeds Beckett University who had a history of borrowing from payday loan companies. Shortly after an unsuccessful attempt to borrow more money, he was found hanging in his student accommodation; concerns included the conduct of payday loan companies and inadequate financial checks.
Read the report on judiciary.uk
× Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Inadequate financial checks
Wider context from the report “(1) The conduct of the payday loan companies contributed to his situation in that they were aware that he had become dependent on the loans and that such dependence was encouraged.
(2) Financial checks were inadequate .
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Encouragement of loan dependence despite awareness of borrower dependence
Wider context from the report “(1) The conduct of the payday loan companies contributed to his situation in that they were aware that he had become dependent on the loans and that such dependence was encouraged .
(2) Financial checks were inadequate.
” Open source report
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Consult on and clarify creditworthiness, affordability and expenditure-assessment rules and guidance.
Verbatim wording from the response “We consulted last July, in CP17/27, on proposed changes to our rules and guidance on assessing creditworthiness (including affordability). These are aimed at further clarifying our regulatory expectations, including that firms must consider the consumer’s ability to repay without taking out further borrowing to do so.”
Source location Response from Financial Conduct Authority Page 3 · response Published 17 June 2018
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Restrict the number of times payday lenders may refinance loans.
Verbatim wording from the response “We also recognise the additional risks associated with high-cost credit products including payday loans. We have restricted the number of times that payday lenders can refinance a loan, and required them to include a prominent risk warning in advertising. This includes signposting customers to the Money Advice Service.”
Source location Response from Financial Conduct Authority Page 4 · response Published 17 June 2018
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Issue a policy statement containing final creditworthiness, affordability and expenditure-assessment rules and guidance.
Verbatim wording from the response “We plan to issue a policy statement, with final rules and guidance, shortly.”
Source location Response from Financial Conduct Authority Page 3 · response Published 17 June 2018
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation No minimum timeframe is specified for creditworthiness assessments because the regulatory approach balances innovation benefits against risks to vulnerable consumers.
Verbatim wording from the response “Our rules cover several areas of pre-contract conduct by lenders. We recognise that automation and innovation is becoming more common place across financial services but we do not specify a minimum timeframe within which a firm’s creditworthiness assessment must take place. While automation and innovation can benefit consumers, we also recognise that it can pose risks to the more vulnerable in society.”
Source location Response from Financial Conduct Authority Page 4 · response Published 17 June 2018
Open published response
5 Sep 2014 Kane Samuel Sparham-Price · Prevention of Future Deaths report Manchester South
View report summary
Concerns raised 1 Lack of a statutory minimum protected bank balance after payday lender deductions View source
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
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AI-generated summary
Kane Samuel Sparham-Price · Prevention of Future Deaths report
This summary was generated using AI from the published report. Please read the original report for the complete account.
Report summary
Kane Samuel Sparham-Price, who had lived much of his life in care and foster homes and had mental health problems, was found hanging at his home after a payday lender took part of the debt from his bank account, leaving him with no money. The concern raised was that payday lenders should be required to leave a statutory minimum amount in a person's account to avoid absolute destitution.
Read the report on judiciary.uk
× Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Financial Conduct Authority; that does not assign responsibility.
PFD Monitor interpretation Lack of a statutory minimum protected bank balance after payday lender deductions
Wider context from the report “As shown in box 5 above, he was left with no money in his account and no means of borrowing any more. Whilst I accept that the various pay-day lenders are legally entitled to ‘clear out’ someone’s bank account if money is owing to them , it struck me that there ought to be a statutory minimum amount which MUST be left in an account (say £10.00) to avoid absolute destitution ; and as I understand you set and regulate the rules, you might look at this with a view to preventing further deaths.
” Open source report
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Proactively supervise authorised high-cost short-term lenders.
Verbatim wording from the response “The authorisation process will rigorously assess the business models of lenders operating in this sector to ensure that consumers are treated fairly. Firms will not be authorised if they cannot demonstrate that they are able to comply with the price cap and other FCA rules, including those on rollovers and CPAs outlined above. Once they are authorised, we will pro-actively supervise these firms.”
Source location 2014-0463-Response-by-Financial-Conduct-Authority Page 3 · response Published 5 September 2014
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Rigorously assess high-cost short-term lenders’ business models through the authorisation process.
Verbatim wording from the response “The authorisation process will rigorously assess the business models of lenders operating in this sector to ensure that consumers are treated fairly. Firms will not be authorised if they cannot demonstrate that they are able to comply with the price cap and other FCA rules, including those on rollovers and CPAs outlined above. Once they are authorised, we will pro-actively supervise these firms.”
Source location 2014-0463-Response-by-Financial-Conduct-Authority Page 3 · response Published 5 September 2014
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Restrict high-cost short-term lenders’ continuous payment authorities to two repayment attempts and prohibit partial-payment collection.
Verbatim wording from the response “As outlined below we have already taken action in this area through the restriction on the use of Continuous Payment Authorities (CPAs) to take partial payments from an account. We believe that this (together with our other conduct standards) will mitigate the likelihood of consumers being left with a zero balance on their account, although we do recognise it is a possibility that only a small balance will remain.”
Source location 2014-0463-Response-by-Financial-Conduct-Authority Page 1 · response Published 5 September 2014
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Existing CPA restrictions and wider conduct, authorisation and supervision rules are considered sufficient to reduce the risk of consumers being left without funds.
Verbatim wording from the response “As outlined below we have already taken action in this area through the restriction on the use of Continuous Payment Authorities (CPAs) to take partial payments from an account. We believe that this (together with our other conduct standards) will mitigate the likelihood of consumers being left with a zero balance on their account, although we do recognise it is a possibility that only a small balance will remain.”
Source location 2014-0463-Response-by-Financial-Conduct-Authority Page 1 · response Published 5 September 2014
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation A statutory £10 minimum balance could create privacy concerns, prove ineffective, leave consumers worse off, or cause failed-payment fees.
Verbatim wording from the response “The ability of lenders to access a consumer’s bank account to ascertain what residual balance may be available would raise significant concerns about privacy. In practical terms, it might”
Source location 2014-0463-Response-by-Financial-Conduct-Authority Page 1 · response Published 5 September 2014
Open published response