PFD report

Naseeb Singh Chuhan · Prevention of Future Deaths report

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Issued 9 Apr 2018•West Yorkshire Eastern

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

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Concerns
2

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
10

Described in responses

Recipients and published responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Concerns raised2

  1. Inadequate financial checks
  2. Encouragement of loan dependence despite awareness of borrower dependence
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.3

  1. Action

    Consult on and clarify creditworthiness, affordability and expenditure-assessment rules and guidance.

    Stated by Financial Conduct AuthorityStated completedThe respondent said that this action was complete when they made their response on 17 June 2018.
  2. Action

    Restrict the number of times payday lenders may refinance loans.

    Stated by Financial Conduct AuthorityStated completedThe respondent said that this action was complete when they made their response on 17 June 2018.
  3. Action

    Issue a policy statement containing final creditworthiness, affordability and expenditure-assessment rules and guidance.

    Stated by Financial Conduct AuthorityStated plannedThe respondent said that this action was planned when they made their response on 17 June 2018.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.1

  1. Position

    No minimum timeframe is specified for creditworthiness assessments because the regulatory approach balances innovation benefits against risks to vulnerable consumers.

    Stated by Financial Conduct AuthorityExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do 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. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do 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. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

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

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

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

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

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.7

  1. 1

    Assess potential intervention in overdraft pricing and monitoring of repeated overdraft use, including possible consumer support measures.

    Stated by Financial Conduct AuthorityStated in progressThe respondent said that this action was in progress when they made their response on 17 June 2018.
  2. 2

    Investigate evidence supplied about firms’ treatment of vulnerable customers and take appropriate supervisory steps where wrongdoing is identified.

    Stated by Financial Conduct AuthorityStated plannedThe respondent said that this action was planned when they made their response on 17 June 2018.
  3. 3

    Invite firms offering innovative alternatives to high-cost credit to work with the FCA and trial their approaches.

    Stated by Financial Conduct AuthorityStated completedThe respondent said that this action was complete when they made their response on 17 June 2018.
  4. 4

    Maintain the high-cost short-term credit price cap and review it again within three years.

    Stated by Financial Conduct AuthorityStated plannedThe respondent said that this action was planned when they made their response on 17 June 2018.
  5. 5

    Require prominent payday-loan advertising risk warnings and signposting to the Money Advice Service.

    Stated by Financial Conduct AuthorityStated completedThe respondent said that this action was complete when they made their response on 17 June 2018.
  6. 6

    Publish findings from the Future Approach to Consumers consultation on consumer vulnerability.

    Stated by Financial Conduct AuthorityStated plannedThe respondent said that this action was planned when they made their response on 17 June 2018.
  7. 7

    Launch a credit-information market study, collect evidence, identify potential remedies and work with relevant regulators.

    Stated by Financial Conduct AuthorityStated plannedThe respondent said that this action was planned when they made their response on 17 June 2018.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.1

  1. 1

    The price cap for high-cost short-term loans was maintained at its current level following review, with another review committed within three years.

    Stated by Financial Conduct AuthorityExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

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

Assess potential intervention in overdraft pricing and monitoring of repeated overdraft use, including possible consumer support measures.

Verbatim wording from the response

“The first is in relation to overdrafts, and particularly the price consumers pay for using them. I note that Mr Chuhan had repeatedly used these. We have published analysis that shows a case for considering more direct intervention in the way that firms price their overdrafts, and we are in the process of inviting views. We are also considering whether and how firms should improve their monitoring of consumers who repeatedly use overdrafts. As part of this, we are looking at how firms could help consumers find the most appropriate form of credit for their needs and to find ways to assist consumers in a pattern of repeated overdraft borrowing. If our further analysis shows that intervention is warranted, we aim to consult on proposed rules by the end of 2018.”

Source location

Response from Financial Conduct Authority
Page 5 · response
Published 17 June 2018

Open published response

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

Investigate evidence supplied about firms’ treatment of vulnerable customers and take appropriate supervisory steps where wrongdoing is identified.

Verbatim wording from the response

“Mr Chuhan’s parents have identified serious concerns about the way in which he was treated by several firms which are authorised by the FCA and, at point 6, ask about the FCA’s powers. We take accusations of harm very seriously and in cases like this look into what may have gone wrong with firms’ systems and controls, which should be designed to identify vulnerable customers. Where we find a firm has failed to act in an appropriate manner we have a number of powers that enable us to intervene. I have asked our supervisory team to look at the evidence provided to us and, where we find wrongdoing, take steps to ensure the firms are acting in an appropriate manner. More generally, our supervisors can refer appropriate cases to enforcement colleagues. Our enforcement powers are described in detail in our Enforcement Guide¹.”

Source location

Response from Financial Conduct Authority
Page 2 · response
Published 17 June 2018

Open published response

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

Invite firms offering innovative alternatives to high-cost credit to work with the FCA and trial their approaches.

Verbatim wording from the response

“Secondly, we are doing work to foster the growth of alternatives to high-cost credit. Greater availability and awareness of alternatives would reduce the number of people turning to high-cost credit services. It would also provide options for consumers who may no longer be able to access high-cost credit after any possible interventions we make. We are keen to improve outcomes for these consumers and in the mid term we think there is scope to explore wider issues with Government and industry. In the short-term, we have already invited firms with innovative alternatives to work with us and trial their approaches.”

Source location

Response from Financial Conduct Authority
Page 5 · response
Published 17 June 2018

Open published response

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

Maintain the high-cost short-term credit price cap and review it again within three years.

Verbatim wording from the response

“We reviewed our price cap recently and published a feedback statement in July 2017 (FS17/2). After careful consideration, we decided to maintain the price cap at its current level, with a commitment to review it again within 3 years.”

Source location

Response from Financial Conduct Authority
Page 5 · response
Published 17 June 2018

Open published response

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

Require prominent payday-loan advertising risk warnings and signposting to the Money Advice Service.

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

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

Publish findings from the Future Approach to Consumers consultation on consumer vulnerability.

Verbatim wording from the response

“Consumer vulnerability is an integral part of our recent Future Approach to Consumers consultation and we will be publishing our findings on this in the summer.”

Source location

Response from Financial Conduct Authority
Page 4 · response
Published 17 June 2018

Open published response

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

Launch a credit-information market study, collect evidence, identify potential remedies and work with relevant regulators.

Verbatim wording from the response

“We announced in our Business Plan for 2018/19 our intention to launch a market study on credit information. We will collect evidence to gain a better understanding of the potential for harm in this market and, if necessary, identify remedies. Our aim is to ensure that this important market works as well as possible to maximise the benefits that it can deliver for consumers. We will work with other relevant regulators, including the Information Commissioner’s Office.”

Source location

Response from Financial Conduct Authority
Page 4 · response
Published 17 June 2018

Open published response

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

The price cap for high-cost short-term loans was maintained at its current level following review, with another review committed within three years.

Verbatim wording from the response

“We too had reservations over the potentially high cost of payday loans. One of our first major initiatives after taking on regulation of consumer credit was to consult on a price cap for high-cost short-term loans. This was introduced in January 2015 and limits interest and fees to 0.8% per day of the amount borrowed, with consumers never having to pay more in interest, fees and charges than the amount they borrowed.”

Source location

Response from Financial Conduct Authority
Page 5 · response
Published 17 June 2018

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Data last updated 7 September 2026