Salad Money Impact Report 22-23 WEB - Flipbook - Page 8
CONSUMER DUTY:
RAISING THE BAR TO
SALAD’S LEVEL
Some in the credit industry
called the new Consumer
Duty, which came into
force on 31 July 2023, a
“tough new regime” or a
“wake up call”.
Others seemed to have their head
in the sand, which the Financial
Conduct Authority (FCA) picked up
on when it reviewed larger 昀椀rms’
implementation plans in early 2023.
Salad welcomed the Duty, which
seeks to ensure “good outcomes” for
customers. This means 昀椀rms should
provide products and services that
昀椀t their needs and o昀昀er fair value.
Customers should receive easy-tounderstand communications. They
should get customer support when
they need it.
James Rose, Salad’s Chief
Commercial O昀케cer, says: “We want
to see the bar raised on consumer
care. We’ve observed harm caused
to 昀椀nancially-vulnerable consumers
by some 昀椀rms. We hope this pushes
the industry to improve practices
to the standards many good 昀椀rms
already met.”
As a social purpose lender, Salad
has always been committed to the
principles required by the Duty.
But we took preparedness and
8
implementation seriously. “We
engaged with the FCA’s consultation
via Responsible Finance,
which represents community
development 昀椀nance institutions,”
says Rose. “Then we undertook
a comprehensive gap analysis
covering every element of our
business practices against the new
regulations.
“That revealed we were already
broadly aligned with the regulations,
which wasn’t a surprise because of
Salad’s ethos and youth.” Salad was
designed from inception to serve
people excluded by mainstream
lenders and re昀氀ect the needs of
昀椀nancially-vulnerable people.
“Paul Scales was appointed
Consumer Duty Board Champion”
adds Rose, “and we convened
a work programme to focus on
four key areas: broadening our
review process to cover the entire
distribution chain, from before
people arrive to after they leave us;
reviewing all communications
through every touch-point; auditing
all processes and policies to
ensure they were appropriate; and
implementing additional governance
to support our customer-centric
culture.
James Rose,
Chief Commercial O昀케cer
“It was a full company e昀昀ort, with
the entire board and executive
team involved weekly and high
engagement from all our sta昀昀.
We’re hopeful the Duty will mean
customers are better supported
by some 昀椀rms which, to be frank,
have failed them. I’m interested to
see how proactive the FCA will be
about those businesses which have
ignored the Duty or which don’t
meet its standards.”
Paul Scales added “Salad has always
placed consumers at the heart
of everything we do. Our people,
processes and technologies are
aligned with the FCA’s objectives
and we welcome the introduction
of Consumer Duty to drive greater
rigour and responsibility in the
market.”
Fair Lending for Key Workers
