Photo of Richard Hoggart, MD of DSG Financial ServicesSeveral weeks
into the latest round of regulation, it seems a good time to
reflect on how we are finding life under the European Consumer
Credit Directive.

If, like us, you are a
broker, or if you are a dealer, you will be aware that the
challenges of working with the CCD have been completely different
from those faced by lenders.

Whether or not the lenders
recognise this is arguable and – to be fair – it isn’t really their
problem. While they have had only one set of procedures to design,
we have had to try and absorb several sets of conflicting
interpretations and create processes to manage them all as
consistently as possible.

On the surface this has been
handled in an organised fashion at DSG, although there was an
uncomfortable element of last minute preparation due to the
challenge of integrating the raft of unfamiliar paperwork into our

This paperwork element is the
most visible challenge of the CCD, and one that dealers seem to
have coped with well. We created videos to ensure our dealers
understood how to handle the paperwork, and they have helped us by
breaking the actions down into simple steps to ensure

As has been discussed in
other forums, however, we can’t expect to hide behind the paperwork
and claim everything will be fine simply because we have a tidy
paper trail.

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There is no chance the claims
management ghouls will let that suffice. The real answer to how
successfully we have handled the CCD can only come from the
customers borrowing the money.

As part of our payout
procedure we have been speaking to every single customer with the
intention of gauging the level of comfort they have with the way
they have been guided through the process.

Asking simple questions such
as “Were the terms and implications explained to you?” and “Do you
feel you had enough uninterrupted time to read and consider the
agreement before signing?” have thrown up some really interesting
responses that will help prevent future problems with

While most customers have
expressed positive responses, we have had about 15% negative
comments about the level of understanding or lack of comfort in how
the sign-up process was managed. In these instances, we have had no
option but to insist on re-signs.

I would urge all other
parties to do so where they are not 100% convinced of compliance or
– more importantly – customer satisfaction.

The true measure of our
success in handling CCD will not be in how much it delays payouts
or complicates administration for lenders and brokers. It will be
the rate of success of complaints to the ombudsman and the
financial cost of rectifying disgruntled customers.

The next step therefore in
implementing the CCD successfully has to be ensuring there are no
disgruntled customers picking up the phone in 18 months

Richard Hoggart is MD of
DSG Financial Services