Response to SRA Consultation: Regulation of consumer credit - the SRA's regulatory arrangements

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1 Response to SRA Consultation: Regulation of consumer credit - the SRA's regulatory arrangements August The Law Society. All rights reserved.

2 Response to SRA Consultation: Regulation of consumer credit - the SRA's regulatory arrangements August 2015 Introduction 1. The Law Society is pleased to note significant progress made in relation to regulation of solicitors consumer credit activities as efforts are made to avoid dual regulation and the additional costs that brings. 2. The Law Society agrees that regulation should be proportionate and clear, and believes that equality impact assessments and the SRA s knowledge and experience from regulating the profession should be utilised to ensure new arrangements are fit for purpose. Insofar as the proposals represent a continuation of the status quo they will be seen as a welcome development for both the profession and users of legal services. Where change results from the new regulation then the impact on costs and of enforcement processes should be examined. Where concurrent powers of enforcement might arise then suitable protocols need to be developed to avoid uncertainty that would undermine the credibility of the regulators and increase their costs. 3. The Law Society notes that the SRA has responded to arguments put forward and that the SRA has been constructively engaging with both the FCA and the profession in recent months, a process that has enabled it to place these sensible and helpful proposals on the table. 4. We recognise that this is a complex and technical area of regulation where the prospect of change has been the cause of considerable uncertainty over the last nine months. In some respects, this consultation raises relatively few new issues but there remain some where uncertainty persists. For example, in relation to the taking of security for credit arrangements (paragraph 13 of the consultation) the SRA appears to underestimate what is seen as a potential problem. In the context of credit being granted, in routine transactions clarification is needed and further detail is provided below at 8.d. 5. Another example where further clarification is still needed is in relation to the question of payments by instalments which will be discussed in more detail in our answer to question 2. Responses to consultation questions Question 1. Do you agree that it is appropriate for the consumer credit activities set out above to be 'prohibited' from regulation by the SRA under Part 20 FSMA? 6. The prohibited activities largely follow those defined in statute and are therefore along the lines expected and would appear appropriate as pure consumer credit activities subject to the points made in relation to each of those prohibited activities made below: 1

3 entering into a regulated credit agreement as lender except where the regulated credit agreement relates to the payment of disbursements or professional fees; a. This would appear sensible and appropriate. exercising, or having the right to exercise, the lender s rights and duties under a regulated credit agreement except where the regulated credit agreement relates to the payment of disbursements or professional fees; b. This would appear sensible and appropriate. entering into a regulated consumer hire agreement as owner; c. The Society finds it difficult to conceive of situations where solicitors would enter into hire agreements. We would therefore be keen to learn from the SRA what situations it has in mind in respect of this prohibition. exercising, or having the right to exercise, the owner s rights and duties under a regulated consumer hire agreement; or d. The comments made above in relation to entering into a regulated consumer hire agreement as owner are also applicable here. operating an electronic system in relation to peer to peer lending or entering into (or exercising or having the right to exercise rights and duties under) a peer to peer lending agreement. e. This would appear sensible and appropriate. 7. Restrictions applying to firms carrying on permitted consumer credit activities will prevent firms from: providing the client with credit card cheques, a credit or store card, credit tokens, running account credit, a current account or high-cost short-term credit a. We assume that SRA takes the view that if firms are undertaking activities such as issuing credit cards, store cards, overdrafts or personal loans as part and parcel of providing legal services they will seek authorisation from FCA. holding a continuous payment authority over the client s account b. The Society has concerns regarding the holding a continuous payment authority over the client's personal account will apply to solicitors undertaking the role of attorney for elderly clients who have lost capacity and such authority is used to pay nursing home fees, insurances and similar matters. It may also apply to estate administration/probate activities though we assume that, the SRA takes the view that the person who originally held the money is 2

4 deceased and the funds in the estate do not belong to the executors/personal representatives personally. Property management functions may also be restricted where acting for passive investment clients. entering into a regulated credit agreement as lender which is secured on land by a legal or equitable mortgage c. The Society refers to the point made in our introduction at paragraph 5. The SRA appears to be distinguish a mortgage from a charge whereas the Society believe that there is no difference in law (paragraph 13 of the consultation). It is unclear what is meant by credit secured on land. If it means secured by way of legal charge, then this is the same as a legal mortgage. The glossary states that a legal or equitable mortgage includes a legal or equitable charge. The SRA appears to be distinguishing a mortgage from other forms of security on land but does not specify what it has in mind. This restriction has been applied, it would seem, on the assumption that it is rare for firms to secure payment of disbursements and professional fees by way of security on land. The Law Society understands that that assumption may not reflect the fact that this is a far more common practice than assumed and would urge the SRA to look at the issue again when it has had the opportunity to learn more about the frequency of arrangements of this nature. d. The position is perhaps summed up in Fisher and Lightwood s Law of Mortgage (14th Edition) where (at 1.11) it is said:... save that an actual legal estate is not created, a legal charge does not differ from an ordinary legal mortgage. We would be keen to receive more clarification from the SRA on this point as there are numerous situations where a charge may be a mechanism for enabling legal services to be continued where a client is without cash resources until settlement of a matter but is in position to give a charge by way of security for incurring debt. acting as lender under a regulated credit agreement which includes a variable rate of interest e. This would appear sensible and appropriate. providing a debt management plan to a client (a debt management plan is a non-statutory agreement between a client and one or more of the client s lenders, the aim of which is to discharge or liquidate the debts by making any payments to a third party which administers and reviews the plan and distributes money to lenders) f. The proposed definition of a debt management plan (set out in the draft amendments to the Scope Rules) and repeated in this restriction presents a number of problems. The current definition appears to 3

5 envisage a solicitor agreeing with a client that the client will pay money (via the solicitor or not) to a third party (debt management firms) which will then distribute the money to lenders. Of course, creditors (given that tax bills, council tax and utility debts are often covered by debt management plans) is a much wider class than lenders. This requires clarification by the SRA as solicitors may well be involved in sorting out payment of a number of long standing payments due to creditors. charging a separate fee for, or attributing any element of the firm s fees to, the provision of credit broking services. g. This would appear sensible and appropriate. Question 2. What is the likely impact of these prohibitions and restrictions for firms and consumers? 8. Payment by Instalments The Society is concerned that more clarity is required in relation to the payment of fees by clients in instalments. Clearly, there will not be a problem if, at the outset of any instructions, agreement is made which would enable the client to make payments in up to 12 instalments over a period of not more than 12 months in the event that the client is unable to settle the bill at the completion of the work. We accept the SRA's analysis that, while the exemption in article 60F will not apply if the agreement to accept payment by instalments is entered into after the debt has been incurred the relevant activity would fall within the Part 20 exemption, as this activity arises out of, or is complementary to, the other professional services that the firm has provided to the client. Therefore, firms would be able to undertake this activity under the SRA s regulation and would not need to be authorised by the FCA. 9. However, what this analysis does not appear to have taken account of is that while the exemption obviates the need for FCA authorisation, it does not make the agreement itself exempt from the Consumer Credit Act 1974 (CCA). The agreement would therefore need to be a regulated agreement and as such be in the form prescribed by the CCA. 10. It appears to the Society that in order to deal with the problem SRA should lobby the Treasury for a widening of the exemption to include refinancing. This would require an amendment of the Regulated Activities Order to include borrower-lender agreements by way of refinancing and these could be expressly limited to professional services within Part 20 of the Financial Services and Markets Act 2000 ( FSMA ). 11. In addition SRA need to provide clarification to firms that the proposed regulation set out in the paper means that when making an agreement with a client for repayment of fees in instalments, the agreement must accord with the parameters of the amended Regulated Activity Order. This needs also to be accompanied by guidance on what solicitors' might usefully include in their 4

6 terms and conditions, details of interest which would be charged in the event that a bill is not settled within the time frame of the original agreement etc. 12. Insurance Mediation We assume that SRA takes the view that, in relation to Insurance Mediation work, the status quo remains with firms being able to continue to benefit from the Part 20 exemptions (extended by the two recent Statutory Instruments). 13. Pro Bono Work The SRA will be aware that in relation to Pro Bono work, practitioners either individually or through law clinics, such as LawWorks, offer consumer credit or debt counselling services. Volunteers at LawWorks Clinics were previously covered to provide consumer credit, credit brokerage, debt-adjusting, debtcounselling, debt collecting, debt administration and the provision of credit information services (including credit repair) by a group licence issued to the Law Society and administered by the SRA. Because of regulatory changes within this area, LawWorks took the cautious decision to advise all of its clinics to stop advising in all areas of consumer credit and debt counselling from 1 April The Society suggests there is scope for bringing pro bono work within the Part 20 regime, on the assumptions that: a) the exemption at article 39K of the FSMA 2000 Regulated Activities Order 2001 would apply on the basis that there would be the provision of "litigation services" within the meaning of art 39(2) because the prospect of litigation will necessarily arise in the context of debt counselling and related work; and b) because either the services are offered pro bono and they therefore are not offered in the course of business, or because they are ancillary to the services being provided and would satisfy the requirements of Part It appears that those not-for-profit bodies, such as the LCN, CABx and Advice UK, that operated with the benefit of an individual Consumer Credit Act 1974 Group Licence to offer debt counselling, debt adjusting and/or credit information services immediately before 1 April 2014, are to be treated as having Part 4A permission to carry on those activities. The Society seeks confirmation that solicitors carrying out work for those bodies will not be affected by the SRA's proposed regime as far as those activities are concerned. LawWorks is also a not-for-profit organisation but did not hold its own group licence prior to 31 March 2014, because advice was being provided by individual solicitors able to operate under the group licence issued to the Law Society, unlike other not-for-profit organisations that required a group licence to cover non-solicitor volunteers. These organisations were therefore issued with a more restrictive group licence. Question 3. Should any of the prohibited activities be allowed, or the prohibitions/restrictions be modified? 5

7 15. As the prohibitions/restrictions largely follow those defined in statute, the Society is not advocating any changes. Question 4. If so, do you believe that any additional consumer protections should be put in place to address any specific risks that these activities present? 16. N/A Question 5. Do you have any comments on the requirements set out in our proposed amendments to the SRA Conduct of Business Rules? 17. With regard to the new Appendix 2, if this amendment is intended to assist firms who are undertaking consumer credit related activities to make a regulated agreement under the Consumer Credit Act 1974 in the prescribed form, then the Society's view is that this annex does not assist. In some ways this ties in with the regulated agreement point. The expression credit-related activities is taken from the FCA s CONC handbook. 18. In relation to the regulation of consumer credit activities when entering into regulated credit agreements, Appendix 2 adopts aspects of the requirements of the FCA s CONC which only apply to regulated credit agreements. Therefore, if there is no change in the exemption and if reliance is not placed on waivers, these requirements will have to be complied with in addition to the CCA rules. The Society would pleased to receive clarification from the SRA that this interpretation is correct. Question 6. Do you have any views about our assessment of the impact of these changes and, are there any impacts, available data or evidence that we should consider in developing our impact assessment? 19. We understand that, the SRA has no data as to the extent that firms enter into consumer credit agreements. We are concerned that the SRA has not obtained relevant data from firms as without this no meaningful impact assessment can be carried out. Bearing in mind the close relationships that SRA has with various firms through its Supervision arrangements a sample set of information ought to be easily obtainable. Such impact assessment is essential bearing in mind the aim of the regulator to reduce the cost burden for firms in complying with regulation and initiatives to reduce red tape. It will be necessary for firms to analyse what is proposed as we are concerned that without relevant data there could be unforeseen impact and costs from changes which affect certain practice areas. Question 7. Can you provide any specific examples of benefits or risks linked to our proposed approach and/or particular aspects our proposed arrangements? 20. The Society urges the SRA to research possible impact and to carefully consider any specific examples that emerge as a result of this consultation, particularly those mentioned by practitioners. 6

8 21. The way in which it is envisaged that supervision and then enforcement may be engaged is not discussed nor is there discussion of areas for ongoing cooperation with FCA where there is common interest or overlap or for action in areas where there is concurrent jurisdiction. 7

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