Information on debt buyers of consumer credit in the UK - April 2023

Firms which carry out regulated debt purchase activity will need to hold permissions for regulated activity A60B(2), exercising or having right to exercise lender's rights and duties under a regulated credit agreement and/or A60N(2), exercising or having the right to exercise the owner's rights and duties under a regulated consumer hire agreement. These permissions must also be held by firms which enter into regulated credit agreements and/or regulated consumer hire agreements respectively. 

Annex A, attached below, includes a list of all the 5,814 firms which were authorised on 17 March 2023 with at least one relevant permission. Although firms may be authorised to carry on the activity and could carry out debt purchase, most are unlikely to do so and do not sit in the Debt Purchasers, Collectors and Administrators (DPCA) portfolio.  

Firms do not need to be authorised to hold regulated debt providing certain criteria, as set out in the Regulated Activities order (RAO) 60i[1] or FSMA exemption order[2], around the recoveries of monies owed are met. These are outside the FCA perimeter and therefore unregulated.

Authorised firms are required to report most regulated A60B consumer credit lending activity on the following data items:

• CCR002 Consumer Credit data: Volumes
• CCR003 Consumer Credit data: Lenders

Firms submit their CCR002 and CCR003 returns for reporting periods which are relative to their own accounting reference dates[3]. For most firms this is only once annually. As a result, we are unable to aggregate this information to reflect a specific calendar period. The table in Annex B below aggregates firms’ CCR002 and CCR003 submissions for their annual reporting periods ending within 12-month periods aligned to calendar years. For example, the column relating to the 12-month period ending December 22, will include any annual reporting periods ending between 1 January 2022 and 31 December 2022.

Following the publication of the Dear CEO letter in 2021, the FCA supervision team undertook a review of statute barred debt across a selection of firms. This piece of multi firm work resulted in feedback which was provided during 2021. This review led to further in-depth work on disputed debt and statute barred debt which was completed in early 2022.  The findings of the review on statue barred debt were included in the February 2023 Dear CEO letter https://landmark-phase.live/publication/correspondence/consumer-duty-portfolio-letter-dpca.pdf%3Cspan class="print-footnote">[4]

In addition to the multi firm work as set out above, the FCA has initiated some bespoke firm engagement with some firms in this portfolio in mid-2022. This work continues.