Consultations
What is a consultation?
Government departments and other policy makers frequently issue consultation documents on proposed new policies and legislation. The CDFA responds to the consultations that are relevant to the CDFI sector, and we welcome input from our members.
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Recent consultations:
Community Investment Tax Relief Reform:
Areas covered include lending requirements, qualifying investments, Revenue costs, the relief rate and type, investor promotion, simplification and use with other funds.
CDFA Response February 2012
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BIS’ Improving Access to Non-Bank Debt: Call for Evidence
“Government will…establish an industry working group, to explore how to further develop access to non‐bank lending channels, including forms of bond issuance, for SME and mid‐sized businesses. The group will be led by the Department for Business,Innovation and Skills and will report by Budget 2012.”Autumn Statement, Nov 2011
Objective
To examine structural and behavioural barriers to the development of alternative debt markets in the UK, building on recent work on this subject, and to makeevidence‐based recommendations to Government ahead of Budget 2012 on practical measures to facilitate the development of these markets.
CDFA Response January 2012
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All Party Parliamentary Small Business Group Entrepreneurship Inquiry
This inquiry by the All Party Parliamentary Small Business Group (APPSBG) will consider the role of entrepreneurs in driving economic growth. It will consider entrepreneurs who already have their own business and budding entrepreneurs looking to set up on their own. It will examine the support available to them and also the barriers they face.
CDFA Response January 2012
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Past consultation responses
A new approach to financial regulation: consultation on reforming the consumer credit regime
CDFA response March 2011
The government is considering combining the current system of regulation by the FSA and OFT, into one succinct department, the Consumer Protection and Markets Authority (CPMA). By transferring the powers of the Act to a central body there is the opportunity for a ‘significant overhaul’ of the current regime. The CDFA calls for prudence in the collaboration of regulation requirements for socially driven credit intermediaries. Great care needs to be taken that any new scheme enacted recognises CDFIs activity as different from high cost for profit bodies and are therefore must be regulated accordingly.
Consumer Debt and Personal Insolvency
CDFA response December 2010
This consultation looks at the regulations and practices of the high cost credit market, with a desire to make the space both fairer and clearer for consumers and borrowers. This includes the need for money advice and debt management programs. The CDFA has asked the government to publicise and scale up the network of personal lending CDFIs, both through funding and the addition of CDFIs on price comparison websites. This would allow consumers to make informed and clear decisions when looking for credit. The CDFI model is championed as a sustainable, yet affordable and ethical way of providing credit to those who need it.
Financing a Private Sector Recovery
CDFA response September 2010
The Government’s green paper on business finance mentioned CDFIs as an important source of credit for SMEs. Our response outlines a number of ways in which the Government can tap into this source to the benefit of businesses around the country.
Regional Growth Fund consultation
CDFA response September 2010
We have submitted answers to the questions posed by the joint departmental consultation on the development of the Regional Growth Fund. The CDFA argues for utilisation of the fund through existing intermediaries, CDFIs and that CDFA could act as a wholesaler for funds specifically to strengthen CDFIs. If working through the Local Enterprise Partnerships we have argued that they must have common understanding of the need to utilise proven models for delivery at the local level, recognizing the value of tried and tested financial mechanisms.
BIS Select Committee Inquiry into Local Enterprise Partnerships
CDFA response August 2010
We have submitted written evidence to this inquiry on the role and functions of the new Local Enterprise Partnerships (LEPs). We argue that LEPs should work with CDFIs on a consistent basis to deliver business finance to underserved markets.
Bills of Sale consultation
CDFA response March 2010
The CDFA has asked for CDFIs to be allowed to continue to use bills of sale to fund unincorporated businesses or sole traders. The Government should overhaul and update regulation so that the Consumer Credit Act supersedes any Bill of Sale agreement, bringing legislation up to date and protecting consumers.
Consumer Credit Licensing Fees
CDFA response March 2010
CDFIs understand the need to be regulated under the Consumer Credit Act, but we believe that paying a fee to the OFT is unfair given their business structure. We propose that CDFIs, like credit unions, should be exempt from paying fees due to their non-profit status and social remit to serve disadvantaged communities.
Developing the banking and financial services available at the Post Office
CDFA response February 2010
The CDFA argues that the Post Office must do more to tackle financial exclusion. This includes working closely with local CDFIs where applicable and utilising their local and trusted status in communities.
HM Treasury Review of Money Laundering Regulations
CDFA response December 2009
With many CDFIs operating in a ‘grey area’ between business and consumer credit, CDFA has called for specific rules and guidelines for the sector to be drawn up, so it is clear which aspects of money laundering regulations CDFIs are required to comply with.
Social Investment Wholesale Bank consultation
CDFA response October 2009
The CDFA supports the mission of a Social Investment Wholesale Bank which assists CDFIs and other retailers in supporting enterprising communities, deprived areas and the financially excluded. In order for such an institution to succeed, CDFIs must be supported in expanding their capacity across the whole of the UK.
OFT High Cost of Credit Review
CDFA response August 2009
The CDFA believes one of the primary issues at stake is the lack of adequate, affordable and universally-accessible credit.Regardless of how the problems inherent in the relativity unregulated high-cost credit industry are remedied, one of the solutions must include the expansion and positioning of a nationwide network of CDFIs and other providers of alternative, affordable credit.
