PayPlan has become the first volume IVA provider to formally adopt the IVA Integrity Score developed by Consumer Duty Services (CDS). PayPlan is one of the largest debt solution providers in the UK, offering holistic debt advice and a full range of debt remedies, formal and informal, across all legal jurisdictions. They are part of the Insolvency Practitioner Association (IPA) volume provider scheme.

For residents in England & Wales, all PayPlan IVA proposals from the start of November 2024 will contain the independent and highly predictive CDS sustainability score. This will enable FCA-regulated creditors and their voting agents to both consider the likely consumer outcome, when deciding how to vote on the Individual Voluntary Arrangement (IVA) proposal, in line with their obligations under the FCA’s Consumer Duty and to clearly demonstrate that consideration.

This will enable PayPlan to ensure they are supporting those consumers entering an IVA with a higher risk of failure and ensure they receive the level of support they need to have the best chance of completing their IVA and clearing the debts in this formal debt solution.

The recent Insolvency Service report on early IVA failures published in October 2024 has highlighted concerns regarding procedures at some insolvency practitioner firms regarding the onboarding of IVA clients. The Integrity Score provides licensed insolvency practitioners and their regulatory professional bodies (RPBs) with the ability to both clearly demonstrate their commitment to delivering sustainable IVAs and providing their consumer customers with the necessary level of long-term support over 5-6 years. With pressures operating costs and recoverable fees, the ability to take a risk-based approach  to deliver the best outcomes for customers is very timely.

John Fairhurst, Director of PayPlan, said:

“We have worked with Peter and Kevin from the start of the Consumer Duty regime and contributed data and knowhow to the Integrity Score development. We have collaborated alongside CDS in regularly updating the underlying IVA performance data, met with regulators and participated in creditor and volume provider forums through 2024. Between the CDS events in May and October 2024, we have continued to Beta test the score and the API to a point where we are comfortable with using it on all of our IVA proposals. We have been able provide refreshed data from younger cases from H2 2023 and 2024.         

“We are committed to the data sharing and API agreement with CDS for the provision of the IVA Integrity Score. We believe it has an important role to play in helping us ensure our indebted customers achieve the best possible outcome. We have also had positive feedback from creditor voting agents, giving us confidence to propose more IVAs, as opposed to longer-term DMPs.”

Peter Wordsworth, Director at CDS, said:

“We are delighted that PayPlan have become the first volume IVA provider to fully integrate the IVA Integrity score into their IVA process and proposals. We have worked closely with PayPlan in the development of the score and we are very appreciative of their support throughout this process. We believe this is an important first step in ensuring more sustainable IVAs are approved across the industry delivering better outcomes for more customers. We have been encouraged by the engagement with regulators throughout the process, including clarification from the FCA of the linkage to the Consumer Duty for regulated participants in the end-to-end customer journey.

“John is joining Kevin and I at the IPA conference on 28 November 2024 to discuss current market developments along with Peter Bowen of Aryza/Evolve. Industry driven initiatives are critical at the moment with a new government in place and more regulatory collaboration. Relying on primary legislation with The Insolvency Service personal insolvency review still underway is unlikely to deliver the change that is required to give consumers, community debt advisers and creditors more confidence in the sector and for lenders and their voting agents to agree to higher fixed fees in a volatile marketplace.”

PayPlan and CDS participated in the personal insolvency reform workshops in May 2024.

The Insolvency Service report on early IVA failures was published on 17 October after the CDS volume IVA provider event on 3 October 2024. Claire Hardgrave, Head of Insolvency Practitioner Regulation at The Insolvency Service, referenced this and a Freedom of Information (FoI) request published on 7 November 2024. She spoke alongside David Holland, Chief Inspector at the IPA. Some relevant links below.

https://www.gov.uk/government/news/research-shows-concerning-level-of-poor-practice-in-the-iva-market

https://insolvency-practitioners.org.uk/regulatory-guidance-on-expectations-for-insolvency-practitioners/

https://www.gov.uk/government/publications/individual-voluntary-arrangement-terminations-by-duration-and-by-debtor-age-and-gender-england-wales-2014-to-q3-2024

About PayPlan

PayPlan is one of the UK’s largest free debt advice providers and helps over 100,000 clients every year. It offers FCA-regulated advice and support to anyone struggling with their finances - along with tailored and sustainable solutions. PayPlan works closely with the free debt advice sector and campaigns for positive change across the industry. It is also the preferred referral partner for many high street lenders - and a range of organisations, including charities, housing associations and employers. Improving accessibility to debt advice is a key focus, particularly for those struggling with vulnerabilities, through digital innovation and awareness raising.

www.PayPlan.com

Media contact to hannah.shipman@PayPlan.com

About Consumer Duty Services

Consumer Duty Services or “CDS” was established by subject matter experts Peter Wordsworth and Kevin Still in 2023 with a simple mission to help our clients to evidence better outcomes for their consumer customers under the FCA Consumer Duty, notably the sustainability of debt remedies like IVAs and Debt Management Plans (DMPs).

We work with lenders, debt buyers, debt advisory firms, creditor voting agents and personal insolvency practices, including their funders. Whilst supporting clients with regulatory compliance across a range of regulated products, our core business is centred on IVA and DMP portfolios.

Our ethos:

• Integrity in all that we do
• Data-driven
• Technology enabled
• Pragmatic and commercial
• Strong Social Values

www.consumerdutyservices.com

Media contact to kevin@consumerdutyservices.com or 07980 859994