Forbearance you can show was appropriate.
We rebuild collections policy and the arrears record so every account shows individual circumstances, a sustainable arrangement and the right treatment of interest.
What the rules require
- Forbearance and due consideration for customers in or approaching arrears (CONC 7.3.4R, CONC 7.3.4AG)
- Individual circumstances taken into account (CONC 7.3.4BR)
- Sustainable arrangements (CONC 7.3.5BR), leaving priority debts and essential living costs covered (CONC 7.3.5CG)
- Income and expenditure assessed objectively (CONC 7.3.5DR)
- Interest and charges reduced, waived or cancelled while an arrangement is kept (CONC 7.3.5GR)
- Forbearance kept under review (CONC 7.3.5IR)
- Signposting to free debt advice (CONC 7.3.7AG)
- Repayment records monitored for early signs of difficulty (CONC 6.7.2R)
Vulnerable customers
Identification, recording and what happened next: support in one-to-one interactions (PRIN 2A.5.9R), outcomes compared across groups of customers (PRIN 2A.9.10R), and mental capacity (CONC 2.10). We also build the vulnerable-customer register, with restricted, audited access.
Software that fits
Questions
Short answers, with the provision each one rests on.
Must a lender stop interest while a customer keeps to a repayment arrangement?
Where a firm has put a repayment arrangement in place as a forbearance measure and the customer is meeting it, the firm must reduce, waive or cancel further interest or charges to the extent necessary to ensure the debt does not rise for the period of the arrangement (CONC 7.3.5GR).
Talk to someone who has done your job.
A 30-minute call, no deck. Bring the problem; we will tell you what we would do.