Embark FCA guidance

Paylinks Embark tool effortlessly enables firms to meet criteria of new FCA Consumer Credit and Coronavirus Guidance 

The most recent FCA guidance came into force on the 2nd October and gives further clarity to firms dealing with customers who have been granted payment deferrals. 

Weve summarised some of the key considerations for firms on how to implement the guidance, but also given an overview of key Embark features that can instantly be enabled to deliver against the guidance.   If youd like any additional information on how Embark can support you with your current payment holiday strategy please get in touch at enquiries@paylinksolutions.co.uk

FCA Guidance Embark Solution
Use of Digital Tools
Point 2.12 of the guidance explains how digital tools can be used to: “Firstly, automate processes including asking borrowers who cannot resume full payments to provide information on their circumstances, including income and expenditure”
The Embark tool uses a combination of Credit Reference Agency (CRA) and Open Banking data to provide an accurate picture of the customer’s financial situation in minutes
“Secondly, offer a customer a forbearance option the firm has identified as appropriate to the customer’s individual circumstances, and get the customer’s agreement to it”
Paylink’s new ‘Digital Triage Hub’ provides firms with a tailored solution which can be adapted to individual customer’s circumstances and allows firms to effectively handle large volumes of customers coming to the end of payment holidays
“Lastly, offer a customer a range of options that the firm has identified as appropriate to the customer’s individual circumstances for the customer to choose from”
A combination of Paylink’s Digital Triage and Arrangements features give customers a number of options from start to end of the digital journey and means that firms don’t experience delays in getting customers to the right outcome.
Support Customers who choose a non-digital route

Section 2.14 of the guidance asks firms to make sure they can provide support to those customer’s choosing a non-digital route                                                                                                                                                                                                                                 

Embark’s agent-led journey means that at any point in the workflow the customer can seamlessly move from self-serve to agent-led at the touch of a button. In cases where the customer requests this from the beginning, the agent can complete the Embark workflow with the customer over the phone. 

Support Customers at the end of a payment deferral period

Section 3.2 re-confirms that firms should take reasonable steps to contact their customers in good time before the end of the payment deferral period 

Embark’s ‘bulk upload’ feature provides firms with a way of contacting their customers in advance of payment holidays ending and Paylink’s bespoke approach to development means that firms can tailor communications to suit different types of customers, including:

Providing information about the next payment due date

What the firm should do if the customer indicates that they might continue to face payment difficulties

A combination of options, including Digital Triage, Arrangements and Referral to Debt Advice then provides customers with different ways in which they can provide an update to the firm, negating the need to increase agent capacity to cope with the expected increases in call volumes.

Sharing records of completed I&Es

Point 5.25 of the new guidance states: 

Where a customer, without prompting or pressure from the firm, makes a proposal to the firm, the firm may put this in place without undertaking an income and expenditure assessment. The firm should make clear to the customer that they can request a review of this arrangement at any time.  

“The firm should also contact the customer after 60 days of the arrangement being in place, to confirm whether they require further support or a review of the sustainability of their arrangement (for example, on the basis of an income and expenditure assessment).” 

Paylink’s Digital Triage Hub provides a central place where customers can propose details of payments they wish to make, and they can be effectively triaged into the correct outcome for the customer. In some cases, Embark can send an automated request to review the arrangement and gain affordability assessment after this event, where applicable.

Customers who’ve completed the Embark journey will already have a downloaded, easy-to-share PDF of their completed I&E if they’re asked to share it. Once more, this means that firms using Embark are in line with the new FCA guidance that not only empowers customers but also allows firms to respond better and more accurately, using less resource during this challenging period.

5.34 of the new guidance states:

“The firm should, where possible and within its existing systems capabilities, share a record of any income and expenditure assessment that they complete with customers or make these available to customers (so that they are able to share them with other lenders) and debt advice providers.

Although firms are not required to rely on information collected by third parties, firms should support and encourage customers to re-use up-to-date income and expenditure information previously gathered where possible. For example, an income and expenditure assessment completed by another lender.”

Embark gives customers a PDF of their completed Income and Expenditure which can be downloaded and shared with other lenders, meaning that firms using Embark are already complying with this new piece of FCA guidance without having to do anything further themselves.

Use of Digital Tools

FCA Guidance

Point 2.12 of the guidance explains how digital tools can be used to:
“Firstly, automate processes including asking borrowers who cannot resume full payments to provide information on their circumstances, including income and expenditure”

Embark Solution

The Embark tool uses a combination of Credit Reference Agency (CRA) and Open Banking data to provide an accurate picture of the customer’s financial situation in minutes

FCA Guidance

“Secondly, offer a customer a forbearance option the firm has identified as appropriate to the customer’s individual circumstances, and get the customer’s agreement to it”

Embark Solution

Paylink’s new ‘Digital Triage Hub’ provides firms with a tailored solution which can be adapted to individual customer’s circumstances and allows firms to effectively handle large volumes of customers coming to the end of payment holidays

FCA Guidance

“Lastly, offer a customer a range of options that the firm has identified as appropriate to the customer’s individual circumstances for the customer to choose from”

Embark Solution

A combination of Paylink’s Digital Triage and Arrangements features give customers a number of options from start to end of the digital journey and means that firms don’t experience delays in getting customers to the right outcome.

Support Customers who choose a non-digital route

FCA Guidance

Section 2.14 of the guidance asks firms to make sure they can provide support to those customer’s choosing a non-digital route

Embark Solution

Embark’s agent-led journey means that at any point in the workflow the customer can seamlessly move from self-serve to agent-led at the touch of a button. In cases where the customer requests this from the beginning, the agent can complete the Embark workflow with the customer over the phone.

Support Customers at the end of a payment deferral period

FCA Guidance

Section 3.2 re-confirms that firms should take reasonable steps to contact their customers in good time before the end of the payment deferral period.

Embark Solution

Embark’s ‘bulk upload’ feature provides firms with a way of contacting their customers in advance of payment holidays ending and Paylink’s bespoke approach to development means that firms can tailor communications to suit different types of customers, including:

  • Providing information about the next payment due date
  • What the firm should do if the customer indicates that they might continue to face payment difficulties
  • A combination of options, including Digital Triage, Arrangements and Referral to Debt Advice then provides customers with different ways in which they can provide an update to the firm, negating the need to increase agent capacity to cope with the expected increases in call volumes.

Sharing records of completed I&Es

FCA Guidance

Point 5.25 of the new guidance states:

“Where a customer, without prompting or pressure from the firm, makes a proposal to the firm, the firm may put this in place without undertaking an income and expenditure assessment. The firm should make clear to the customer that they can request a review of this arrangement at any time.

“The firm should also contact the customer after 60 days of the arrangement being in place, to confirm whether they require further support or a review of the sustainability of their arrangement (for example, on the basis of an income and expenditure assessment).”

Embark Solution

  • Paylink’s Digital Triage Hub provides a central place where customers can propose details of payments they wish to make, and they can be effectively triaged into the correct outcome for the customer. In some cases, Embark can send an automated request to review the arrangement and gain affordability assessment after this event, where applicable.
  • Customers who’ve completed the Embark journey will already have a downloaded, easy-to-share PDF of their completed I&E if they’re asked to share it. Once more, this means that firms using Embark are in line with the new FCA guidance that not only empowers customers but also allows firms to respond better and more accurately, using less resource during this challenging period.

FCA Guidance

5.34 of the new guidance states:

“The firm should, where possible and within its existing systems capabilities, share a record of any income and expenditure assessment that they complete with customers or make these available to customers (so that they are able to share them with other lenders) and debt advice providers.

Although firms are not required to rely on information collected by third parties, firms should support and encourage customers to re-use up-to-date income and expenditure information previously gathered where possible. For example, an income and expenditure assessment completed by another lender.”

Embark Solution

Embark gives customers a PDF of their completed Income and Expenditure which can be downloaded and shared with other lenders, meaning that firms using Embark are already complying with this new piece of FCA guidance without having to do anything further themselves.