The stimulus for this engagement was the enforcement moratorium, which we believe disproportionately and negatively impacted a large number of short-term lenders and customers, as it disregarded the unique characteristics of the short-term mortgage lending market, compared to the term market.
It’s fair to say that to date we have made greater progress in our dialogue with Treasury than with the FCA, but I am positive about the lines of communication that we have established with both.
Now that we have opened the door, I believe it is imperative we continue to maintain this dialogue and it is important that we do not do so in isolation.
At the ASTL Annual Conference, I spoke about the importance of liaison with our peer groups at FIBA, the NACFB and AMI.
I firmly believe that the closer we are, the better our ability to be recognised and engaged with by the Treasury and the FCA.
I can’t see any point in ploughing our own furrows independently of each other. We have nothing to fear from either the Treasury or the FCA while we are in concert together.
Continue to engage
The fear I have is that unless we are in regular and meaningful dialogue with the regulators and that we speak the same story, further far reaching decisions will be made by them and the potential issue of unintended consequences will remain real.
With the end of the enforcement moratorium and FCA guidance transitioning back towards working with customers on an individual basis, our initial purpose for engagement with the regulators is receding.
However, I am determined this will not mark the end of our dialogue, but rather just the end of a first chapter of a more meaningful, consistent and collaborative period of communication.
The moratorium may be abating, but its impact may be with us for some time yet. Even more important therefore that we co-operate and engage.