Non Bank Lending
Alongside the rapid development of fintech and open banking, non-banking has grown in significance, offering a wide variety of specialist and novel services, ranging from peer-to-peer lending to high rate, short term loans. As is often the case, the rapid pace of innovation can easily outstrip our ability to foresee consequences including consumer outcomes.
The pressure of pandemic-related financial pressure across the economy has added to the regulatory focus on all lending firms’ assessment of customer outcomes, and the FCA has conducted thematic reviews on forbearance in general and in relation to specific pandemic measures. The results of these reviews are impacting lending firms and leading to internal and independent reviews of past business, as well as procedural and training revisions.
Our Approach
We provide a comprehensive range of services to support non-bank lenders across the range of compliance and regulatory challenges that are priorities for the sector, including:
- Consumer duty, retail conduct rules and their wider implications - product and service governance and design, and outcomes monitoring
- Forbearance and arrears - handling arrears and forbearance well, and in compliance with the complex requirements to ensure good customer outcomes
- Past business reviews - design, execution, and assurance, to ensure the PBR includes the full scope of customers, properly stratified, and fairly but efficiently assesses financial and non-financial detriment and redress according to FCA and FOS rules or methodologies
- Vulnerable customers - ensuring vulnerable customers are properly identified and handled throughout the customer lifecycle, including arrears, forbearance and PBR situations
