Money Advice Service Achieving consistent and high quality Debt Advice. Consultation - Community Housing Cymru Response

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1 Money Advice Service Achieving consistent and high quality Debt Advice Consultation - Community Housing Cymru Response 1. About Us Community Housing Cymru (CHC) is the representative body for housing associations and community mutuals in Wales. Our members provide approximately 153,000 homes across Wales and invest heavily in housing-led regeneration and social care. In 2011/12, our members directly employed 7,500 people and spent over 850m in the Welsh economy. 1 In July 2010, CHC formed a group structure with Care & Repair Cymru and CREW Regeneration Wales to jointly champion not-for-profit housing, care and regeneration. In 2011, Community Housing Cymru set up a money advice project, funded by the Big Lottery and Welsh Water. The money advice project was initially set up to provide independent money advice to Moneyline Cymru customers. Moneyline Cymru is a responsible, not-for-profit lender with a presence in 6 local authorities in South East Wales and planned expansion to Swansea and Wrexham, plus a telephone service to provide access for rural areas. Since then, CHC s money advice project has expanded and has partnered with housing associations and Welsh Water to provide money advice to their customers. The project plans to expand geographically alongside Moneyline Cymru and also widen its remit by assisting those who are impacted by welfare reform. CHC s team of 7 money advisers have also been closely involved with the campaign. Question 1 Is there additional value in using a Money Advice Service logo linked to the relevant Quality Standard badge that is customer facing so that it is widely recognisable to the public? As a general point we feel that as a sector we need to be accountable for our actions and ensure that any advice we deliver is independent and of a high quality. Often housing 1 Measuring the Economic Impact of Welsh Housing Associations, November 2012

2 associations have no other choice but to provide money advice to tenants due to local availability and often housing associations are best-placed to provide preventative advice to tenants who might not otherwise engage with other agencies. To this end we must ensure that there is protection for both client and housing association. We feel there is additional value to using a recognisable and trusted brand linked to a relevant Quality Standard. Feedback from the evaluation of CHC s money advice project told us that customers and stakeholders had difficulty differentiating between the services of ourselves and those of our host organisation. A recognised brand would help with public recognition and perceptions of the service. Our experience with the start-up and development of the Your Benefits are Changing campaign and Moneyline Cymru branding is that both customers and stakeholders respond positively to consistent, well thought out branding. The MAS is fast becoming a household name through regular and consistent promotion of the brand and service. Brand recognition has no doubt improved by recent improvements to their advertising campaigns which better suit their target audience. Additionally, a Quality Standard would have been very useful guidance for CHC when setting up the money advice project. The proposed framework will provide a good basis on which to build a service and would have been extremely useful for us when we were setting up ours. We welcome the development of a strong brand and logo and the opportunity to achieve the related standards. We feel this can only be beneficial for the sector and CHC s money advice project. Whilst we cannot expect service users to understand the complexities of funding arrangements and our relationship with any partners, familiarity with a brand or logo would certainly assist with the identification of the availability of money advice. Building an independent Quality Standard will provide consistency across the board, irrespective of the size or aims and objectives of the organisation or any additional services they offer. For example, a customer utilising the services of a housing association, credit union, Moneyline Cymru or CAB could have confidence that they can expect to receive the same quality in money advice and that the adviser / organisation is part of a larger network. Question 2 Which standards or membership codes do you consider to fully meet our Framework? Please provide detailed evidence of how they can demonstrate this. CHC s money advice team have already attained or expected to work towards the Institute of Money Advisers Certificate in Money Advice. Although this qualification covers subjects which are over and above the remit of the service, it was felt that it would be beneficial for

3 both advisers and service users if this was the expected standard. This also has the benefit of providing flexibility for service users and stakeholders, should roles expand or change.. However, some members felt that Wiser Adviser might be the most appropriate awarding body, since the IMA Certificate might be too advanced and irrelevant to their day to day work. In these cases the IMA Certificate might prohibit some advisers from accessing the Quality Standard. Question 3 Are there any quality requirements that should be included or excluded from the Framework? Please explain why. We are happy with the requirements set out in the framework and have not identified any further requirements. Question 4 Are the role profiles identified correct and reflective of best practice across the sector? We feel the role profiles will be very helpful with regards to attaining consistency across the sector and providing clarification with regards to roles, responsibilities and, additionally, potentially provide consistency in terms of salary. The role of the specialist debt advisers who work in the Citizens Advice specialist money advice unit, for example, have not been recognised here. Throughout the proposal document there are constant references to debt advice or debt adviser ; indeed, the consultation title is about debt advice. We feel that the generic term money adviser is more relevant in many cases where debt advice is not part of the service provided. Many of our members provide advice around financial products such as bank and savings accounts and general budgeting, and these types of services should be provided for in a Quality Standard. Question 5 Have the appropriate NOS been used within the role profiles? Please explain any suggested changes. We feel that the NOS are appropriate for the role profiles included in the proposals.

4 Question 6 Which debt qualifications and training courses have been developed using the NOS? Please provide details of which NOS have been used. As we are not a qualification owner we are unable to respond to this question. Question 7 Are there other requirements that a sole debt adviser should evidence? Sole debt advisers should be: Holders of an OFT Consumer Credit License Members of the IMA / Advice UK / or members of a similar professional body In addition, sole debt or money advisers should evidence that they are not working in isolation and are attending regular meetings where they can share good practice and case law updates. For this reason, CHC has started a sector Adviser Network for members who employ advisers including welfare benefit, money, fuel poverty and digital inclusion. Question 8 Do you agree that this is the appropriate approach to evidencing the quality of individuals delivering debt advice? Please provide details of any suggested alternative approaches. We believe that peer reviews not only between housing associations but also between other stakeholders should play an important part in evidencing the quality of those delivering advice. This will encourage best practice and consistency cross-sector and benefit both service users and stakeholders. Question 9 Currently different standards owners use a variety of accreditation processes. How often is it appropriate for standards owners to monitor and review compliance against their standard? CHC s own money advice team is working towards its own self-monitoring and compliance which involves self-supervising and file reviews. We are piloting this with another organisation who would peer-review our files and vice versa. We suggest annual peer

5 review, particularly for individuals, which would involve inspection of random files and the development of a tool similar to that of the Legal Services Commission. Questions 10 and 11 How often should the Money Advice Service review standards against our Quality Framework? Should the Money Advice Service appoint an independent third party to conduct a verification audit of organisations working to the standards that meet the Quality Framework? We suggest a 3 year review which would fit in with many funding cycles. An annual review would be too onerous for many organisations and could be a barrier to applying for the Quality Standard. The MAS should appoint an independent third party to undertake this work, preferably an existing auditor. Clare Williams Community Housing Cymru March 2013