A key factor in the decision to take out high‐cost credit is often the ease and availability of online lending with immediate decisions together with a lack of awareness about more affordable alternatives. Consumer awareness of credit unions and CDFIs is relatively low, especially when compared to many high‐cost lenders. This section therefore summarises relevant evidence and resources to support the effective promotion and awareness raising of affordable finance, to help divert residents away from high-cost lenders and towards alternative and more appropriate sources of support.
The legal framework for promoting affordable finance
Credit-related activity, including credit broking (the introduction and referral of individuals to sources of credit) is a regulated activity, that is usually likely to require authorisation by the Financial Conduct Authority (FCA).
Importantly, local authorities are specifically excluded from the legal requirement to be authorised for most credit-related regulated activities, including credit broking, as detailed in the FCA’s Perimeter Guidance: PERG 2.9.23G.
Those authorities that provide social housing, however, may find the following FCA guidance note of interest: FG18/6: Helping tenants find alternatives to high-cost credit and what this means for social housing landlords.
This document aims to help social housing landlords, including local authorities and housing associations understand the scope and application of consumer credit regulation when they help tenants to find alternatives to high-cost credit, such as loans from credit unions or CDFI’s. The FCA recognise that social landlords can play a key role in this area, helping to create better options for consumers that could provide them with a cheaper, lower-risk source of finance. In recognition of this context, in July 2019 the law introduced an important exclusion for social housing landlords from the scope of credit broking. It is important to note, however, that this exclusion only applies where:
- the activity concerned is affecting an introduction of an individual who wishes to enter into a credit agreement
- the introduction is to a credit union, community benefit society, registered charity (or subsidiary of a registered charity), community interest company limited by guarantee or subsidiary of an RSL, and
- the introduction is provided fee free, i.e. the RSL receives no fee (which includes money or any other financial consideration).
The guidance note can be accessed via this link, and any enquiries can be made to the FCA’s dedicated social housing team via: [email protected].
The importance of promoting affordable finance
The direct promotion and marketing of local affordable finance provision is critical to diverting residents away from high-cost lenders. Unfortunately, the services available via credit unions or CDFIs can often struggle to be heard against these high-cost lenders, backed by significant marketing budgets and a highly visible digital and media presence. Additionally, for many of those in vulnerable circumstances who are looking at credit options, it can be hard to see beyond the weekly cost that is often the focus of advertising, and to recognise the longer-term financial implications of high-cost credit. Research by the Centre for Responsible Credit on behalf of Fair For You, evidenced that before finding their way to Fair for You, 80% of their customers had borrowed from other sources in the previous 12 months, including 36% from doorstep lenders and 29% from the rent-to-own sector.
Save as you borrow
Beyond the direct financial benefit provided by paying less interest, compared to higher-cost borrowing, the effective promotion of affordable lending also provides a gateway to other affordable and responsible financial services and is often the critical ‘hook’ that can be used to initially catch consumer attention. “Save as you borrow” (SAYB) is the practice of credit unions to encourage their members to make savings contributions as part of their regular loan repayments – as illustrated by the example below, from London Mutual Credit Union.
As evidenced by the Fairbanking Foundation, the SAYB model of lending helps to build savings habits and thus financial resilience. With its ease, the savings provide security and the lump sum at the end of the loan and the sense of achievement, all or which are beneficial to the customer.
For those who have rarely or never saved, the well-being benefits are tangible – as most are motivated to continue the painless practice they have begun. It identified that 26% of participants who accessed a SAYB product, were saving regularly before they borrowed, but an additional 45% stated they would sustain their new savings habit in the future.
Recommendations for local authorities
The promotion of affordable and responsible finance by local authorities is also advocated by the FCA. In their Alternatives to High-Cost Credit Report, the FCA note that local authorities sit at the centre of their community and have a key role in promoting economic growth in their area.
Additionally, they highlight that given their responsibility for essential and support services, they are in a unique position to communicate with and signpost consumers to relevant services. The report therefore outlines a number of recommendations relevant to local authorities on promotion and awareness-raising of affordable and responsible credit:
- Local authorities and other frontline service providers, such as RSL’s and relevant charities, should consider providing their service users with information about affordable lending alternatives, embedded within their regular service delivery.
- A lot of the existing information about lower-cost credit options could be made more prominent and accessible, particularly online. The most accessible webpages are those that can be easily found from the homepage, for example via clear menus or headings such as ‘Help with your borrowing’ or ‘Getting the best deal on loans’.
- The quality of signposting of helpful information about the characteristics of credit union and CDFI loans could be improved by including illustrative and interactive information to increase consumer awareness of lower cost borrowing options – as per the table below.
- Alongside promotion of affordable lending options, consumers should also be signposted to additional sources of further information and support, such as the Money and Pensions Advice website.
Promoting lending and interest rates
There is often a negative public perception about the interest rates charged by community finance providers and concern about actively promoting such loans, particularly when they are compared against mainstream borrowing options, such as bank credit cards and loans. It is important to recognise, however, that many people are unable to access this lower-cost credit as they are financially vulnerable, on low or unstable incomes or have a bad credit history. Many vulnerable, low-income households with a legitimate need for credit, to cover income gaps or emergency expenses for example, therefore access high-cost credit (such as doorstep or payday loans) because they do not have, or perceive that they do not have, any other alternative.
In addition, there is also a social cost to households accessing subprime credit. For example, nearly two thirds (60%) of Fair For You customers who had previously borrowed from other higher-cost sources reported that this borrowing had created significant difficulties for them – 36% said it had led to stress or anxiety about money, 32% that their credit score had suffered and 23% had to cut back on essential spending to make the repayments.
As the table below illustrates, this borrowing is significantly more expensive than that offered by community finance providers, who also provide wraparound support to build financial stability and resilience.
Borrowing £400 over 6 months / 26 weeks
|
London Mutual Credit Union |
Conduit |
Provident |
Satsuma Loans |
Mr Lender |
Type of lender
|
Credit Union
|
CDFI
|
Home credit
|
HCSTC
|
HCSTC
|
Representative rate (APR)
|
42.6%
|
99.8%
|
535%
|
*not provided
|
1,242%
|
Amount of interest
|
£43
|
£87
|
£436
|
£358
|
£364
|
Total repayable
|
£443
|
£487
|
£624
|
£758
|
£764
|
Source: Price quotes taken from company websites on 23 March 2021. For exact quotes please refer to the company websites.
Partnership approaches
Marketing is identified as the top barrier to growth by affordable credit providers. However, given their role as local leaders and partnership co-ordinators, councils are well placed to help affordable lenders to develop and deliver comprehensive, sustained promotional campaigns that amplify their message and help to reach new audiences.
Good credit project: Sheffield City Region
In the run-up to Christmas, the Good Credit project ran a public campaign across various channels to promote access to affordable credit within South Yorkshire – directing people to the project website with listing of affordable credit providers. As a result, Sheffield Credit Union made 37% more loans in December 2019 compared to December 2018 – Good Credit Index.
Hull Money
Hull Money was established in 2018 by CDFI Five Lamps in partnership with Hull City Council, advice agencies and other local organisations. It provides a single branded gateway for customers when they need local financial services including savings, loans, white goods and advice. The online hub links customers directly to their provider of choice, which in terms of affordable lending includes both Hull and East Yorkshire Credit Union and CDFI Conduit.
Our Newham Money
Our Newham Money adopts a similar approach to Hull Money (and Northumberland Money) offering a single portal for coordinated financial support and services for residents in the London Borough of Newham.
The service is run by Newham Council, who work in partnership with London Community Credit Union to provide easy and straightforward access to affordable and responsible credit.
Effective communication and engagement
Research on the behavioural and psychological impacts of poverty highlights the detriment that financial worries, poverty and being in vulnerable situations can have on decision making and the ability to take positive action. Poverty has significant cognitive and psychological aspects, eroding self-esteem and self-confidence and generating feelings of helplessness and fear of dependence. Research has evidenced that when people on lower incomes suffer from financial pressure, the drop in their cognitive function is equivalent to an entire night’s sleep.
The table below therefore highlights some useful resources to support effective communication and engagement, within this context, across advice and support services, including the provision of affordable credit.
Poverty and decision making: how behavioural science can improve opportunity in the UK
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This research report by the Joseph Rowntree Foundation highlights the impact that financial worries, poverty and being in vulnerable situations can have on decision making and the ability to take positive action.
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Better Money Behaviours
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The London Housing Financial Inclusion Group sponsored report, Better Money Behaviours, provides a behaviour change toolkit for engaging people on money issues – the toolkit outlines 12 principles for effective engagement.
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The EAST framework
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The Behavioural Insight Team has developed a simple framework to help organisations to deliver effective behavioural approaches. In their report, they have identified four simple principles (Easy, Attractive, Social and Timely – EAST) to encourage positive behaviour change, that can be adopted and implemented across the delivery of activity to tackle financial hardship.
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Key considerations
Promotional and awareness raising activity should be informed by relevant behavioural insights research and resources to ensure that it is as engaging and effective as possible. Activity should be targeted to ensure that those most in need can find out about the support available and this should include the use of partners working with vulnerable residents.
Practical opportunities to embed relevant information, resources and support tools across council activity and processes should be mapped out and prioritised. For example, embedding reference to local affordable finance provision and the ‘stop the loan sharks’ team within relevant council tax communication processes. External resources and tools can also be used to add value to local information.