3.3Data collection andregulatory returns

We acknowledge that the FCA seeks to be data-led in pursuit of its objectives. But the increasing volumes of information it seeks does not feel proportionate for our sector and places a significant additional resource and cost burden on our members. Reporting requirements impact the ‘cost to serve’ consumers and may even reduce competition in the market if firms (particularly smaller ones serving their local communities) deem the cost of providing a service outweighs the benefits of providing it.

In its report on the secondary international competitiveness and growth objective, the FCA outlined plans for a pilot framework for decommissioning regulatory data collections that are no longer required, as well as the progressive review and retirement of redundant returns. We believe this is a necessary intervention and should be brought forward at the earliest opportunity.

For the FCA to optimise reporting expectations based on size and scale of businesses and consolidate requests on firms to avoid the disproportionate costs this has on smaller firms.

The 2024 Consultation
on Consumer Credit Regulatory Returns

 

This proposed that firms would have to supply an extensive range of data that they do not currently collect and may have no need for. Supplying it would take considerable IT system changes as well as staff training and increased MI reporting capabilities. As an example of how this proposal would pressure resources and take people away from helping customers, one premium finance provider said that of 114 lines of data to be required from a credit broker, they could only supply 19 lines (17%) of it currently. The cost to implement the requirement would fall disproportionately on smaller firms.