Listening Phase Report - Money and Pensions Service - Summary of discussions with stakeholders about our evidence base, priorities and ambitions ...
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Money and Pensions Service Listening Phase Report Summary of discussions with stakeholders about our evidence base, priorities and ambitions 1
Contents Contents .................................................................................................................................................. 2 Executive Summary................................................................................................................................. 3 Start young ............................................................................................................................................ 10 Put savings first ..................................................................................................................................... 13 Make the credit market work for everyone ......................................................................................... 15 Make debt advice work better for consumers and funders ................................................................. 17 Embed pensions and retirement planning as a lifelong issue .............................................................. 21 Address unique needs of people in later life ........................................................................................ 25 Prioritise gender and mental health gaps............................................................................................. 27 Digital engagement ............................................................................................................................... 29 Make the business case to engage retail financial services.................................................................. 31 Be the backbone ................................................................................................................................... 32 Views on MaPS Corporate Strategy ...................................................................................................... 33 Next steps ............................................................................................................................................. 36 Appendices............................................................................................................................................ 37 2
Executive Summary Between April and June 2019, the Money and Pensions Service (MaPS) conducted an intensive listening phase across the UK to engage with a wide range of stakeholders and levy payers. The objective of the listening events and other activities was to help MaPS to formulate a new UK Strategy for Financial Wellbeing (published alongside this document), and our three-year Corporate Strategy. Since we embarked on the listening phase, we emerging thinking on future priorities, as well have decided to publish: as a sense that messages were being actively heard from a wide range of audiences and • a one-year Corporate Plan for 2020/21 in incorporated into the strategy development Spring 2020, and process. Emerging content shared during the • our three-year Corporate Strategy for listening phase was also generally welcomed 2021/22 – 2023/24 in Autumn 2020. by stakeholders. This will ensure that the MaPS Corporate This document summarises the feedback Strategy is aligned to the UK Strategy for received from stakeholders during our Financial Wellbeing (UK Strategy) delivery listening phase. plans to be developed by challenge groups in Given the wealth of input we received1, this the activation period following publication of document can only be a selected summary of the UK Strategy. stakeholder comments and suggestions that Feedback provided by stakeholders during the ranged across a very broad financial capability listening phase has been a vital ingredient in and wellbeing landscape. developing the UK Strategy and our one-year We aim to present a fair and balanced view of Corporate Plan. It will also greatly inform our what stakeholders told us, including areas three-year Corporate Strategy. where there was consensus; where there was We surveyed those who attended the regional disagreement; and where we considered a roadshows, and received a very positive single comment, or a couple, particularly response from stakeholders all across the UK. noteworthy contributions to the debate. Those who took part in the listening phase We hope everyone who contributed to the appreciated the fact that senior leaders took listening phase will find this document useful time to listen. They also particularly in understanding the general consensus and appreciated the opportunity to hear about our response to what we heard. 1 More than 1,000 stakeholders - from a range of backgrounds including employers, business groups, policy makers, local government, current and potential delivery partners, educators, front line charities and local practitioners - attended events during the listening phase, and more than 600 pages of written responses were received from 39 different organisations. 3
Core principles What stakeholders said in the listening phase Put the customer first struggling’ segments are unable to achieve financial resilience because they simply do not A clear and consistent message throughout the have enough money coming in due to changes listening phase was that both the UK Strategy in work and the economy” (Citizens Advice and the MaPS Corporate Strategy should start Scotland). from the needs of customers and the customer outcomes that we want to affect. Services People in vulnerable circumstances / should be designed with the most vulnerable in most in need mind, which would result in services that work for everyone. As one stakeholder commented, With regard to establishing vulnerability and “we must put the client at the centre of the most in need customer groups, the key points service delivery” (Community Advice and Law raised by stakeholders were: Service). • Strong consensus that MaPS’ approach to Outcomes and target customer groups vulnerability should be aligned to the FCA definition of vulnerability that is generally While there was considerable comment about understood and accepted. “MaPS should specific outcomes (for example some align to the FCA’s definition of vulnerability” respondents questioned the debt advice target (UK Finance). of 500,000 more people obtaining debt advice), • People can move in and out of a vulnerable there was relatively little feedback about the situation, and vulnerability can occur process for prioritising competing outcomes suddenly. “It is not strictly possible to make and goals. As a result, the MaPS Board has had a clean distinction. Financial capability to exercise judgement in order to prioritise. efforts should contain an element of ‘risk of vulnerability’…” (MyBnk). “MaPS should focus on increasing reach across • The Money Advice Service’s focus on money, pensions, and debt guidance and advice vulnerable groups for debt commissioning service… any targets set should be made in was seen as being too narrow, and MaPS consultation and flexible to the way people seek was encouraged to ensure that the advice and the need to continue to improve the segmentation model address vulnerability quality of help people get… MaPS should also more broadly, and not just vulnerability continue to measure the quality of delivered relating to low incomes. and commissioned services… MaPS should set • Mental health difficulties are seen as a realistic targets for its impact at a general leading area of vulnerability. The UK and population level. In the first instance MaPS MaPS Corporate Strategies must meet the should set outcome targets for the population it needs of consumers with mental health reaches. In combination with the reach difficulties across both money and pensions. measures this should ensure both an increasing number of people helped with targets that • Economic abuse is widespread – people MaPS can easily hold itself and its partners to often fall into financial difficulties because account against” (Citizens Advice). they’re in a coercive / abusive relationship. • Consider the needs of digitally disengaged With regard to target customer groups, many customers, especially considering more and stakeholders urged MaPS to consider the broad more products and services are provided socio-economic context in which target digitally / via digital platforms. customer groups are living. “People in the ‘financially squeezed’ and ‘financially 4
• MaPS must reach consumers in vulnerable guidance and, where appropriate, advice” circumstances where they are, through (Barclays). partnerships with trusted intermediaries and This approach involves much greater community groups, rather than expecting integration of money and pensions guidance them to come to MaPS. “The best way to and debt advice. It also means recognising that reach the most in need and most vulnerable people aren’t only individuals – they have is to deliver advice to people where they relationships with others in families and need it. That means co-locating, investing in communities too. All of this can have an partnerships, and promoting referrals influence on how people interact and how they between agencies” (Citizens Advice). “MaPS deal with money. cannot reach those most in need or in vulnerable circumstances by itself because Moreover, while people may initially present primarily it is a strategic body and not a with issues relating to money or pensions, the delivery organisation. MaPS needs to work underlying causes might be entirely different – with existing organisations who are already for example gambling, mental health issues, or engaged with this demographic…who can the breakdown of a relationship. If we want to best identify and reach them” (Citizens improve money and pensions outcomes for Advice Scotland). customers, we have to help people address • At the same time, MaPS service design must these root causes. This may mean developing build in the needs of consumers in partnerships, training, better referrals or vulnerable circumstances. integrating services and support across the sector. Treat needs holistically More prevention A consistent message from the listening phase was that money, pensions, debt and financial There was a clear message from stakeholders education are not totally separate topics – that there is an urgent and increasing need for people’s lives don’t work like that. Both the UK what some described as “crisis support” (mainly Strategy and the MaPS Corporate Strategy debt advice). should therefore offer support across the whole spectrum of money issues people face, when One stakeholder noted that “more and more and where they need it. people present to debt advice because of an unforeseen (and unmanageable) event, or “[The creation of] MaPS is an opportunity to because their level of income cannot sustain an commission and support more holistic services” acceptable living standard. MaPS’ ability to (Citizens Advice). influence these structural socio-economic issues is likely to be limited. [People coming to debt “We would encourage MaPS to prioritise a advice] are well aware of the benefits of having whole-of-life approach to advice and guidance, savings to fall back on…but many of them just in which considerations about short-term don’t have the means to save” (Money Advice financial resilience are integrated with long- Scotland). term pension saving to achieve good outcomes over the course of a consumer’s life” (NEST). “Growing numbers of people also need to be supported right now [by debt advice]. The “[We] would encourage MaPS to consider the budget for crisis debt advice needs to be opportunities for data sharing between advice sustained at the current level as a minimum or and guidance providers, such that providers increased” (The Money Advice Trust). have more holistic views of client need and can tailor information and advice appropriately. We At the same time, there was general support for believe there is significant potential for an API- the view that, in order to truly move the dials based ecosystem for advice and guidance, and achieve the UK Strategy and Corporate through which consumers consent to share data vision, a much greater focus on prevention is with providers in order to receive more tailored required. Improving access to high quality 5
financial education, getting better at identifying “MaPS should look to influence the background people who are likely to fall into debt, and cultural environment of attitudes to investing. helping people to plan for retirement before it The UK is held back from securing better is too late, are all aspects of this shift towards financial futures by excessively conservative prevention. attitudes to investing and a propensity to hold long term savings in cash” (Hargreaves “MaPS will fail to achieve its aim of positively Lansdown). impacting the whole population if support is restricted to ‘crisis’ work…MaPS should allocate Respect devolution a higher proportion of its budget to preventative work…Within the preventative Stakeholders strongly emphasised the budget there should be a relative move from importance of developing strategies and plans further evidence gathering and piloting that fit with the different legislative and policy (although this remains important), towards environments in all the nations of the UK. Even funding proven interventions that can be where legislation is not devolved, policies and expanded at scale and with the infrastructure to approaches may vary, and this should be taken ensure high and consistent quality” (MyBnk). into account. Detailed plans should be produced and be specific to the conditions of “As with health services, we believe prevention each nation. should take priority over cure given the scope to help greater numbers of people and the limited As one public sector organisation commented, resources MaPS has at its disposal” (Just “this does mean that [MaPS] needs to be willing Group). to be sufficiently flexible about differing priorities and delivery [across the UK]” Specific recommendations (National Advice Network, Wales). Specific recommendations that were proposed Similarly in Northern Ireland, the Strategy by stakeholders at listening events and in should reflect the specific needs of consumers written submissions included: in Northern Ireland, for example “Northern Ireland specific baseline figures and specific Key • Education at the point of taking out credit Performance Indicators (KPI), which seek to (using behavioural insights or compulsion) have a real impact for consumers in the region” • Earlier, more sensitive, signposting (Consumer Council NI). MaPS was also urged to to support continue to have a local presence “to best understand the specific needs of Northern Ireland consumers” (Consumer Council NI). Change the culture MaPS was also urged to forge close working Stakeholders encouraged us to help build a relationships with governments and key culture of openness where people are much stakeholders, and to ensure that sufficient staff more comfortable talking about issues relating and resources were dedicated to “retaining to money and pensions with friends and family. relationships, working closely with and We were for example urged to consider influencing…Government and other…national education campaigns to reduce the stigma of stakeholders” (National Advice Network, debt and financial difficulties, to influence Wales). attitudes to saving, and to promote planning for retirement and thinking about pension options. In Wales, the importance of making sure that strategies, delivery plans and services fully “MaPS should continue to maintain a public- embrace the Welsh language was highlighted. facing element with the aim of increasing the This would not merely meet legislative social acceptability and confidence of ‘talking requirements but also “ensure that any service about money’ and the public support of delivery is appropriate and relevant for people financial education to improve financial and in a bilingual nation” (National Advice general well-being” (MyBnk). Network, Wales). 6
Specifically with regard to debt advice, partnership with an external organisation” stakeholders pointed out that MaPS needed to (Hargreaves Lansdown). achieve a careful balancing act. “Whilst MaPS has a responsibility under the Act to have a Go to where people are national debt strategy it will have to be very Many stakeholders expressed the view that in careful that the strategy sits lightly enough to order for MaPS to help more people make the enable the devolved authorities to make their most of their money and pensions, support own decisions on the appropriate use of the should be embedded where consumers already funding, without restraint. If it sets a debt go physically or virtually, rather than MaPS strategy that doesn’t meet the needs of the investing heavily in getting people to go to different nations in the UK MaPS risks MaPS. “We would encourage MaPS to seek to irrelevance given that the money already sits work with sectors with existing reach, with the devolved authorities. So it is very much architecture and consumer touch points to land up to MaPS to ensure that it does not side-line messages at scale” (UK Finance). This might itself by not being cognizant of the sensitivities include working with employers (see section in the devolved nations around this issue” below), housing associations, GPs, retailers and (Citizens Advice Scotland). others (including hyper-local community based Stakeholders encouraged us to call the strategy organisations). It might also involve providing the “UK Strategy” rather than the “National syndicated online content and tools where Strategy” to avoid confusion. people are already engaging online – for example through banking, gaming or intranet Complement rather than duplicate sites. Finally it was also seen as important for MaPS to develop a local presence, rather than (This is a core principle relevant to both the UK relying solely on national initiatives. and Corporate Strategies, but perhaps more applicable to the MaPS Corporate Strategy). Employers Stakeholders were very clear in the listening “Creating a culture of financial health at work phase that MaPS must recognise what is could have a profound impact on outcomes for already happening in the wider sector and seek consumers” (Association of British Insurers). to complement and improve on what exists. Only where there are clear gaps should MaPS “There is substantial potential for MaPS to seek to create new initiatives. Even then, MaPS improve financial capability by working closely should first look to define the problem and fund with employers and workplace pension others to find solutions, before resorting to schemes” (Pensions and Lifetime Savings delivering services itself. Association). There was a strong consensus among Employers generally focus on what the law says stakeholders that MaPS “should not ‘reinvent they must do (for example, auto-enrolment), the wheel’ and should share effective good whereas staff tend to be more concerned about practice that works by promoting stakeholders’ borrowing, debt consolidation, building savings, activities and working in partnerships with and protection. existing organisations” (Fairbanking Many employers want to provide more help to Foundation). their staff, but are concerned about over- “The default assumption should be that for stepping the regulatory boundary. This is many customer needs, an external solution particularly the case with smaller employers. already available is likely to be better than There was particular enthusiasm for MaPS to MaPS building a new one from scratch. There work with and support smaller employers will always be exceptions, such as the pension around financial wellbeing. “MaPS should invest dashboard, however a solution delivered by in digital tools and other means to reach the MaPS is always likely to be more expensive, and small employer community, and help them to slower to deliver, than one developed in 7
find ways to support their staff with both • Develop a peer-support training package pension saving and broader financial wellbeing” within the workplace (e.g. financial first (NEST). “MaPS needs to work in partnership aider). with a wide range of organisations. Employers • Instill a culture of financial wellbeing within are particularly important here and we think the DNA of the workplace – for example by more emphasis should be placed on SME developing a framework or charter: “MaPS employers who now employ 60% of the private should promote a ‘financial capability sector workforce” (Financial Resilience Task charter’ among employers, committing Force). employers to funded financial capability support for their employees” (The Money Specific recommendations Charity). Some specific recommendations that were • Improve communications between proposed by stakeholders at listening events employers and government to boost and in written submissions included: understanding and take-up of beneficial policies. • Create an employer platform to provide • Engage government to introduce tax seamless access to affordable credit, pay incentives for employers to offer payroll advances and insurance – and to consolidate saving. debts, repay loans or build savings (e.g. • Normalise employer reporting on financial through payroll deduction schemes). wellbeing in annual reports • Redesign and promote the employer portal built by MAS but little used. How we’re responding Put the customer first More prevention Customer outcomes are at the heart of the UK The public health model pyramid of prevention, Strategy. The UK Strategy sets five key early intervention, and crisis support has been a outcomes, each with a priority measure and a helpful stimulus to our thinking about the UK 2030 National Goal. It also sets out the Strategy. This has raised the question of where customer groups we believe are most in need the balance lies across the range of total for each priority measure. provision within the system, and whether MaPS should focus particularly on any specific level of We will align the MaPS definition of the pyramid. This latter question will be vulnerability to that used by the FCA. addressed in the MaPS three-year Corporate Treat needs holistically Strategy. We fully agree that customer needs should be Change the culture addressed holistically in relation to service We have developed five Agendas for Change as design and delivery, because very often part of the UK Strategy to drive change at scale. financial issues are part of a complex mix of These are broad campaigns or programmes that considerations. In practice the priorities of the mobilise a wide range of organisations. UK Strategy (“Agendas for Change”) will not be Achieving the ambitious goals set out in the treated as separate silos. At the same time, we Agendas for Change will have a transformative felt that it was important to articulate the effect on the culture of financial wellbeing. strategy by clearly setting out the distinct Moreover, the UK Strategy has a strong focus customer outcomes that we are driving towards on financial education, and encouraging in order to achieve the overall financial children and young people to be open about wellbeing vision. talking about money. 8
Respect devolution Complement rather than duplicate We have named the strategy the “UK Strategy”, MaPS will focus on gaps in provision/networks rather than the more ambiguous “National and work collaboratively with a wide range of Strategy”. The UK Strategy has been developed organisations across the sector. This will form a with a view to making sure that legislative and core theme of the MaPS Corporate Strategy. policy differences in different nations are taken into account from the start, and MaPS has kept Go to where people are national governments fully updated as the work In every Agenda for Change we have identified has progressed. asks to key partners that will deliver services to The activation period which follows the where people are. publication of the UK Strategy will involve the In relation to employers in particular, a creation of separate and detailed delivery plans challenge group will drive forward the thinking that are consistent with the overall UK Strategy during the activation period, to establish a but adapted to the specific needs and “workplace proposition”. The group will circumstances of each nation. consider: best practice; issues and barriers to The UK Strategy has been translated into the adoption across the UK workplace; innovations Welsh language. for driving the five National Goals of the UK Strategy; how to scale and how to build the business case; the role of government; and what support is needed to drive this forward. 9
Start young What stakeholders said in the listening phase Stakeholders agreed that: schools these should be facilitated by an educational intermediary. The intermediary • starting early and involving parents is critical can support the school to make the most of to providing children and young people the volunteer opportunity to support existing with a meaningful financial education and provision, but can also support the volunteer setting them on the path to financial to prepare them for how to engage wellbeing as adults effectively, create the most impact, and • too few young people are receiving financial importantly, how to get the most out of the education experience for themselves” (Young Money). • and there are huge variations in the quality and consistency of what is currently being Financial education in schools delivered. Positive engagement from government There was general support for the priorities departments across all UK nations (for example MaPS proposed for action: including support for the Financial Education Conference for School Leaders in England, held • “We absolutely support the importance of in July 2019), indicates strong support for using both teachable moments and just in financial education. time education to maximise the impact of financial education on children and young There is also a strong appetite from teachers people, however this should not be at the and education professionals to learn from each expense of schools developing a progressive other and share approaches through programme of financial education across the professional bodies, unions and other channels. whole school” (Young Money). There is support from the teaching community • “We strongly support starting financial for the co-ordination of high-quality teaching education as young as possible. We feel that resources across financial education. There was parental influence in early years is crucial, as a perception, particularly at the listening is consistent provision through primary events, that many educators lack confidence in education. It is [however] also important delivering financial education, and that this was that focus on secondary education…is not an important area of focus for the future, forgotten” (Young Money). This was echoed perhaps by encouraging and promoting by other stakeholders: “In scaling up, the ‘teacher evangelists’ who do have the core secondary school programme should confidence to speak about the topic. play a key role. We suggest this be added explicitly to the list of priorities” (The Money At the same time, concern was expressed that Charity). The need to maintain momentum support for the principle of financial education in financial education throughout the years did not seem to have translated into a of schooling was a common theme echoed significantly increased focus on the topic in the by stakeholders attending the listening classroom. One stakeholder suggested that events. MaPS would need to “advocate with • “We see the use of industry experts as a government, parliament and civil society with hugely valuable way of engaging young UK educational authorities including DfE and people in real life experiences of the financial Ofsted. To build the case for financial education services sector and making effective use of we suggest that MaPS emphasise the need for expert knowledge and experience…To make financial education to have a clear ‘home’ the most of volunteer opportunities within within PSHE and a designated responsible leader within the school” (MyBnk). 10
Moreover, it was remarked that “the absence of Other specific recommendations [a] plan within the UK education system to meet the targets MaPS is setting needs to remedied if Some specific recommendations that were these goals are to be met. It is important to proposed by stakeholders at listening events know what is expected from each contributor and in written submissions included: (public and private) and how all the contributions fit together to achieve the goals” • Influence the Ofsted Inspection Framework: (MyBnk). “The way to bring financial education centre- stage in schools is to require it to be Home and community settings examined and inspected, so there are actual consequences of not providing learners with While it was agreed that schools are the place effective financial education” (The Money to start, the importance of non-school settings Charity) – “[this] could be a game changer in was also highlighted in relation to new legal how schools treat the subject” (MyBnk) requirements of local authorities to provide • Develop an over-arching framework that financial guidance to care leavers and to creates cultural change, embedding financial prevent homelessness. In addition, as education across all school ages. numerous participants at our roadshows noted, • ‘Auto-enrol’ children and young people into some of the young people most in need of a basic bank account / savings account. support are not engaged in the school system, • Find ways to harness the influencing power so an exclusive focus on financial education in of social media (including to talk about schools would not reach or engage them. digital money topics) – this was a common Funding and the case for financial theme across the listening events. • Use young people as ambassadors to education promote the importance of financial In relation to the challenge of how we can fund wellbeing. financial education, “MaPS needs to support • Collaborate with UK Finance and others to programmes that can be scaled to engage a ensure accessibility for all children and significant proportion of the UK population. This young people to bank accounts and saving means facilitating and supporting sustainable products. funding to up-scale financial education in • Coordinate a plan for maturation of Child schools. A cross government departmental Trust Fund for first cohort of young people effort with the Department for Education, (September 2020). incorporating Ofsted and HM Treasury • Seek to influence policy priorities supported by private sector funding” (MyBnk). appropriate to the specific circumstances of It was suggested by other stakeholders that each UK nation (e.g. ensuring participation MaPS should focus on improving awareness and in the OECD PISA financial literacy test, uptake of existing scale programmes and encouraging addition of financial education supporting providers of those programmes to in the primary school National Curriculum, fill gaps in provision. “Key to this is supporting collaborating with DfE to ensure all T-levels marketing of resources to educators and contain a financial education element) helping educators understand how financial (Young Money). capability can be embedded in a wider range of subjects beyond maths and PHSE” (Barclays). The need to build a compelling case for the wider benefits of financial education was also made by stakeholders. “Unless we are able to show the benefits of embedded, high-quality, financial education to…stakeholders there will remain children and young people who are not effectively reached” (Young Money). 11
How we’re responding We have developed a ‘Financial Foundations’ infrastructure of networks, tools and Agenda for Change in the UK Strategy. Its aim is frameworks to make sure that children and young people • Communicate and engage with educators, get a meaningful financial education, so that parents and community services to promote they become adults able to make the most of practical opportunities for children to learn their money and pensions. This builds on the more and gain valuable experience in comprehensive Commissioning Plan for managing money. Children and Young People developed by the Money Advice Service in 2018. MaPS’ immediate focus will be to bring together influential and relevant stakeholders In particular it will focus on three areas: and partners. They will be set the UK Strategy challenge of how to make sure that 2m more • Schools and further education colleges – we children and young people receive a meaningful want more teachers to have the confidence, financial education. They will also consider skills and knowledge to teach financial specific, short and medium-term proposals such education. We also want more schools and as: colleges to be able to deliver memorable financial education, to different year groups, • Planning a new collaboration on financial as part of a coherent ‘whole school’ education between UK Finance and MaPS. approach. This will involve bringing together financial • Home – how parents show, teach and talk services firms to develop shared priorities about money has a huge influence on that secure high-quality learning about children. We want more children to get money for all children and young people. experience and responsibility for managing • Developing a collaborative pocket money money at home. This includes opportunities campaign to reach children and parents, for spending and budgeting (such as using a focusing on giving children and young bank account). Every child should receive or people more responsibility for their money handle money regularly, even if only a very and opportunities to make age appropriate small amount. money decisions. • Community – extra help is needed to make • How to further develop MaPS’ existing work sure children in more vulnerable on three ‘pathfinder’ projects that increase circumstances get a meaningful financial the scale of financial education. These education. This means targeted support for pathfinders will build more evidence and children in care and leaving care, young experience where we know the biggest carers and disabled young people. We want impact can be made. They fill gaps in to see leaders of organisations that work provision for parents, teacher-training and closely with children and young people support for 16- to 17-year olds. trained and supported. They can then deliver effective financial education for Some stakeholders were keen for MaPS to act children and families. as a vocal advocate with Government departments. Lobbying is not within the remit We believe that priorities for the UK Strategy of MaPS. But we do see it as our role to Financial Foundations work are to: collaborate with DfE and devolved nations, to move forward the financial education agenda in • Boost funding from a range of sources into an impactful and sustainable way, including evidence-based approaches to financial advising on where the evidence points in policy education development. • Scale up effective financial education solutions by providing a supportive 12
Put savings first What stakeholders said in the listening phase There was broad agreement from stakeholders should be seen as both short- and long-term that “not enough people are saving and do not saving (to include saving for retirement through have enough financial resilience as a result” pensions). Other stakeholders pointed out the (Pensions and Lifetime Savings Association). importance of protection products that help to safeguard income, mitigate the impact of The importance of building up a liquid savings shocks such as serious illness, bereavement or buffer and developing a regular savings habit redundancy and generally improve financial was agreed on by stakeholders, especially as resilience. this has a positive knock on benefit for other customer outcomes and on overall financial Other specific recommendations wellbeing. “A lack of financial resilience causes misery for thousands of households across the • Encourage policy change towards savings country. An inability to cope with income shocks auto-enrolment: “Similar nudge-based or unexpected bills can lead to a debt spiral and approaches [to pensions auto-enrolment] severe financial detriment” (Association of can help some of the population to save, British Insurers). Saving provides some making them more resilient when a crisis resilience when financial shocks happen to happens, thus freeing up resources for those individuals so it is less likely they will need to most in need” (Citizens Advice Scotland). seek debt advice. • ‘Pledged Savings Accounts’ are a useful tool to promote savings – this is where an Some stakeholders made the point that savings individual taking out credit also commits to and credit are closely related, and that savings saving at the same time. How we’re responding We have developed an Agenda for Change in we still believe that the overall call for a regular the UK Strategy to build a ‘Nation of Savers’. Its savings habit is the most important message. aim is to make sure that people get a savings habit, build cash reserves to help with In particular the UK Strategy ‘Nation of Savers’ short-term emergencies, and have a clearer work will focus on four areas: future focus in their financial lives. • Getting more people to save every or most We recognise that savings and credit are often, months. but not always, closely linked. So this strategic • Encouraging changes in websites, apps and priority (Agenda for Change) is closely other systems that people use daily to make connected to the ‘Credit Counts’ Agenda for saving simpler. We want it to be much easier Change. It is also linked to the ‘Future Focus’ to put money into savings, no matter how Agenda for Change, which focuses on planning small the amount, and for people to have to for, and in, later life – although getting people think twice about taking it out. to save into very long-term products, such as • Encouraging more people to engage with pensions, requires a different set of enablers the future as saving requires. We want them and measurements. to be confident that saving is worthwhile and secured by the financial system. We do not ignore the fact that for many people, • Changing the national conversation, so insurance and life assurance products are the saving is seen as valuable and attractive. We only things that can protect them against also want to focus that conversation on catastrophic, rather than small, risks. However, banked savings, rather than on 13
money-saving tips. Otherwise, money saved to get a savings habit. Over the long-term in tends to be spent on other items. the national media, we want to persuade influencers to start focusing on the habit and We believe that priorities for the UK Strategy value of banking savings, rather than are to: spending them elsewhere. • Achieve a game-changing shift in the ease of • Encourage Government initiatives focused saving (money in the bank) driven by on savings. Help to Save is a major initiative automation, integration and technology. for people on low incomes. Six million young Changes to systems could make significant adults will have access to savings from the differences to the rates of saving by former Child Trust Funds over the next providing nudges and even auto-enrolment seven years. Both provide infrastructure that schemes. One of the most significant areas is can extend the reach of a savings habit into payroll savings. The ‘sidecar savings’ field new sections of the population. trial, co-funded by MaPS and JP Morgan and MaPS’ immediate focus will be to bring delivered by NEST Insight, is central to our together a group of influential and relevant thinking on automated savings. This concept stakeholders and partners. They will be set the of a savings buffer being built up by people UK Strategy challenge of how to make sure that auto-enrolled in pensions savings seems 2m more ‘struggling’ and ‘squeezed’ people promising. If evidence demonstrates it has a save regularly. The group will also consider positive impact on financial wellbeing, it specific, short and medium-term proposals such could be adopted voluntarily by employers. as: It could even be taken up as a development in law and policy. This could bring about • Greatly increasing the scale and take-up of massive change that is easy and manageable payroll saving schemes. If employees opt to for millions of working people. have their savings deducted from payroll at • Develop a sector-wide programme, including source, it is easy for them to get the habit. multiple forms of messaging direct to Although payroll deducted savings are consumers, to promote a savings habit and available, take-up is low. We would like to say why it is valuable. This could occur at explore proposals to bring this offer to many levels. The rollout of the Standard hundreds of thousands more employees Financial Statement in debt advice, with its within two years. savings element, is a good example. This is • Planning an impactful social campaign. What challenging the idea that people who are is the 10-year plan to change the national overindebted don’t have the capacity or will conversation about savings in the media? 14
Make the credit market work for everyone What stakeholders said in the listening phase Many stakeholders broadly welcomed the approach aligns to regulatory interventions proposed focus on making the credit market around persistent debt and high cost credit. work for everyone. Further, MaPS will need to ensure its messages reflect that customers may be using credit for At the same time, some organisations, sound reasons (e.g. to iron out uneven particularly those involved in providing credit, income/expenditure), or because they have no emphasised the need for a more nuanced other option and in reality need debt advice” understanding of the varied reasons consumers (Barclays). use credit; an appreciation that credit may, in certain circumstances, be the most appropriate Support a broader role for credit unions product solution; and careful positioning of proposed solutions. Credit unions have a higher policy profile with devolved governments as well as higher “Credit is a legitimate way for individuals and customer numbers as a percentage of the householders to smooth income and population than is the case in England. At the expenditure….In addition to tight budgets, there same time, credit unions face strong are many other reasons why customers may use competition from firms offering better headline credit on a regular basis. Credit can be rates, incentives and/or eligibility criteria on beneficial to individuals who can borrow money loans, insurance or savings products. They also to buy goods such as a car or white goods when struggle to engage employers on they are needed, using credit to smooth their loan-repayment or savings payroll-deduction income. Customers may also use credit when schemes. they want to avoid digging into savings which are for a specific purpose. As a result of Some stakeholders felt that MaPS should take increasing flexibility in labour markets and new steps to support credit unions, for example to ways of working, not all individuals receive their help: income in the same way…Increasing numbers of • Engage employers about the benefits of consumers have lifestyles based on uneven financial wellbeing, in particular for earnings and access to different types of credit frictionless payroll deductions for loan products is needed to meet their needs. The repayments and savings. alternative for some consumers might be no • Improve customer journeys for affordable credit available to them. Inability to access credit and insurance and for savings credit can push consumers into avoidable debt. schemes. Given that a proportion of customers are in a • Persuade the FCA and government to allow situation where their finances are stretched to credit unions to expand the range/supply of the limit, an objective of increasing saving and their product offer to consumers (for reducing the use of credit for everyday spending example to offer secured loans or is unlikely to be realistic or achievable in the mortgages). short-term” (Consumer Finance Association). “MaPS will need to work closely with the FCA around inappropriate credit use to ensure its 15
How we’re responding We have developed a ‘Credit Counts’ Agenda and partners. They will be set the UK Strategy for Change in the UK Strategy. Its aim is to make challenge of how to make sure that 2m fewer sure that more people access affordable credit, adults use credit for everyday essentials. and that more people make informed choices about borrowing. They will also consider specific, short and medium-term proposals such as personalised In particular it will focus on four areas: payment schedules in social housing. How we can build on the Rentflex concept? (This is the • Making new forms of low-cost credit proven principle of a personalised schedule for available in the market, and making existing social housing costs, offered alongside free forms of low-cost credit more accessible. financial guidance). Could we develop proposals • Focusing consumer interfaces with credit for scaling it to hundreds of thousands of more on repayment, the total cost of credit, tenants within two years? And how could the and building in elements of savings and principle be seeded into the private rented budgeting. sector, student accommodation marketplace, • Helping consumers to become more mindful and other sectors, such as utilities and Council about the pros and cons of credit, and Tax, that serve our target audience? savvier shoppers on price. • Encouraging creditors to support borrowers Fair4All Finance has been set up to increase the more, through a wider range of financial resilience and wellbeing of those in interventions at an earlier stage when bills vulnerable circumstances in England and Wales. and commitments are missed. The initiative makes suitable, affordable financial products and services readily available, We believe the priorities for the UK Strategy with a focus on increasing access to affordable ‘Credit Counts’ work are to: credit. Fair4All Finance are creating a sector • Continue to support advances made by the Theory of Change with stakeholders. During the FCA to protect consumers from harmful activation period, Fair4All Finance will develop a detailed action plan with stakeholders to lending practices, in particular those in vulnerable circumstances as we understand deliver the key outcomes identified. MaPS will more about their lives. support this exercise, and will look in particular at how awareness of credit choices and suitable • Use technological advances to design debt advice can be developed to support the products to better support the needs and delivery of outcomes in the Theory of Change. preferences of consumers and their choices and behaviours. This will help drive longer With regard to credit unions, we will encourage term financial wellbeing. them to contribute to the goals of the UK • Increase consumer awareness of the options Strategy, in particular in relation to achieving a they have. Choices need to be presented credit market that is fair, sustainable and more clearly, making decisions easier. affordable. • Increase availability of affordable credit choices. This will make a significant Some stakeholders felt that MaPS should difference to the financial wellbeing of those actively lobby Government departments to in the most vulnerable circumstances in highlight the impact of policies such as universal society. credit and wider austerity measures are having in relation to credit use. However the MaPS MaPS’ immediate focus will be to bring Board is clear that lobbying is not within the together influential and relevant stakeholders remit of MaPS. 16
Make debt advice work better for consumers and funders What stakeholders said in the listening phase Debt advice is a key priority Balance requirements for volume and “MaPS main priority must be supporting people quality in crisis-need to get debt advice when they need Stakeholders felt that in relation to debt it, in addition to the MaPS pension work…we services it funds, MaPS put too much emphasis know that debt advice works and helps to on numbers and not enough emphasis on the improve people’s financial capability, that there quality of interactions and the types of clients, is currently considerable unmet need and that and that as a result there were unrealistic the future outlook is that more people will find targets for funded organisations, and excessive themselves in financial difficulty. With existing pressure on individual advisers already dealing with benefits changes, regulatory and other services at capacity, it is important that there is requirements, and the immediate and often a safety net there for everyone who needs it complex needs of clients. now. To achieve the needed increase in capacity, MaPS must focus on supporting “We urge MaPS to avoid getting caught up in a collaborative working, building on existing numbers game as they seek to demonstrate an expertise and investing in shared technology” increase in outputs” (The Money Advice Trust). (The Money Advice Trust). A more collaborative approach to setting “…the demand for debt advice is and will targets and managing performance was urged, as well as greater focus on customer outcomes remain high in the foreseeable future and the rather than volumes. provision of debt advice must remain a top priority” (Community Advice and Law Services). Many stakeholders felt that MaPS should focus on quality and impact, rather than total Intervene early numbers of people reached by debt advice. MaPS was asked to give greater trust to debt Stakeholders agreed that the UK Strategy providers, and to introduce longer term should encourage organisations to identify and sustainable funding that reflected a more support people before they get into debt. A joined up approach, so that frontline providers utility company for example highlighted their could offer holistic support and address the work to identify customers who they believe root causes of debt problems as well as are on the verge of getting into debt, as well as presenting issues. helping customers already in debt and fuel poverty. Improving collections practices “Consumers need to be encouraged to seek debt Stakeholders highlighted the need for a change in practices of local councils so that they looked assistance as early as possible, as evidence to provide help and referred to debt advice suggests that early intervention generates the when people fall into arrears, rather than most effective and sustainable benefits to referring immediately to bailiffs. There is also a consumers, creditors and our wider society” significant cross-departmental agenda to (Gregory Pennington Ltd, part of Think Money improve Central Government debt collections Group). and enforcement practice, led by the Cabinet Office. 17
Creating a sustainable long-term Other specific recommendations model, and broadening the funding Some specific recommendations that were base proposed by stakeholders at listening events There was broad agreement on the need to and in written submissions included: evolve the funding model to ensure all creditors • Engage with employers and with other play a fair and reasonable role. organisations who see people who may be in “MaPS’ key priority must be establishing an financial difficulty presenting with other equitable and sustainable model for funding issues (e.g. GPs). • Leverage technology, social media and free debt advice” (Finance and Leasing influencers (e.g. Martin Lewis) to Association). disseminate the right messages and tackle “MaPS should focus on broadening the funding the stigma around debt and talking about for debt advice and ensure that the burden of money issues generally. funding does not fall primarily on financial • Enable delivery organisations and services firms” (Consumer Finance Association). practitioners to make choices and decisions about service and quality (for example “Debt advice delivers financial benefits for allowing organisations to offer light-touch creditors outside of the financial services sector, interventions where they feel that would be and their contribution to the cost of providing more impactful for consumers). advice should a factor of funding • Proactively send sensitive letters when discussions…MaPS should look to build a more people are starting to fall into difficulty, holistic funding model that reflects drivers of signposting where they can get help. • Discuss the funding challenges with the CEOs demand for debt advice and broadens funding of key firms, and/or with member base” (UK Finance). organisations via trade bodies, with a view “The current funding settlement for debt advice to encouraging an increase in voluntary is inadequate; it does not provide for sufficient funding for debt advice in the short term. If capacity in the sector and the funding that it additional voluntary funding isn’t forthcoming, MaPS and Government should does provide is too narrowly drawn from consider other options. financial services, failing to reflect that demand • Consider engaging independent consultancy for debt advice is often driven by other support to help design long term funding sectors…MaPS should work with HM Treasury, options for debt advice. This might include Department for Work and Pensions and the basing funding on measures of impaired Financial Conduct Authority to create a new lending/arrears, or harnessing funding funding settlement which increases available mechanisms for SDRP. funding and, critically, broadens the funding • Develop mechanism (with published base to all sectors who drive demand for debt metrics) to establish whether debt advice advice” (Barclays). given is effective or provides value for money. • Introduce a standard debt qualification for advisers. How we’re responding We have developed a ‘Better Debt Advice’ receive high quality debt advice when they Agenda for Change in the UK Strategy. Its aim is need it, because of stronger and earlier to make sure that people can access and 18
engagement, and because funding, supply and adequate training, development and good services more closely match need. practice sharing. • Reduce the number of customers needing In particular it will focus on five areas: debt crisis support in the long run. This • Bringing supply and demand closer together. requires shifting the negative culture around Delivering on the direction set by the seeking advice to a positive one, and Wyman Review, to ensure that debt advice delivering preventative measures set out in is available to more of those who need it, the UK Strategy. It also requires better underpinned by a fair and sustainable designed services, built around more funding model. rounded advice, including enhanced money • Ensuring everyone who seeks help gets high guidance and onward referrals from debt quality advice, and there are appropriate advice to help people deal with other options for every person advised, including underlying issues. Promoting creditor good those whose essential expenditure is higher practice in supporting those at risk of, or than their income. experiencing, financial problems, will also be • Building on the Breathing Space scheme, needed. making it the norm to get help with debt MaPS’ immediate focus will be to bring problems. Ensuring that more customers together a group of influential and relevant seek or are referred into appropriate stakeholders and partners. They will be set the support at an earlier stage. UK Strategy challenge of how to make sure that • Developing and implementing a sector-wide 2m more adults can access debt advice. The approach to data, evidence and reporting. group will also consider specific, short and The aim is to reduce duplication, enable a medium-term proposals such as: coherent understanding of impact, and foster improvement at all stages of the client • Developing a set of recommendations for a journey. new funding model. A joint Financial • Encouraging progressive creditor practices. Conduct Authority/MaPS taskforce will The aim is to encourage creditors to design produce a set of recommendations on a products and services in a way that reduces fairer and more sustainable funding model – the likelihood of over-indebtedness seeking input from the sector throughout occurring in the first place. And for it to the process. become the norm for creditors to make • Setting out how to deliver the new debt effective referrals to debt advice and engage advice target operating model, including collaboratively with the debt advice process establishing action plans for the elements of when people do fall into arrears. the PACE model that haven’t yet been mobilised. The PACE model will be built and We believe that priorities for the UK Strategy delivered in collaboration with the debt ‘Better Debt Advice’ work are to: advice and creditor sectors, and will put the client at the heart of services. • Implement the target operating model • Working with HM Treasury and the agreed with the sector in late 2018 through Insolvency Service, we will ensure that this sector-wide infrastructure and approaches. Agenda for Change aligns with Breathing These will include PACE (Piloting Adviser Space and the Statutory Debt Repayment Capacity and Efficiency), the Breathing Space Plan. scheme and the move to a more sustainable long-term funding model. • Measuring the need for debt advice. This is a complex task, different from assessing • Ensure a coordinated, coherent plan for supply or demand. Different measures and delivery across the sector. opinions exist across the sector. MaPS will • Keep and recruit the required skills in the undertake a major review of all the available sector. This includes making sure that being statistics and make recommendations to a debt adviser continues to be an appealing, share with the sector. aspirational profession, and providing 19
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