The Financial Inclusion Centre

New analysis by the Financial Inclusion Centre (FIC) finds that county court judgments (CCJs) are nearly four times more prevalent in the worst affected parliamentary constituencies in England and Wales compared with better-off areas.

FIC analysed unique data from non-profit Registry Trust[1] along with wider economic and financial indicators, such as household incomes and take up of Universal Credit, to build a profile of financial vulnerability in parliamentary constituencies and local authorities across England and Wales.

The report can be found here: FIC Geography of Financial Vulnerability report September 2026

The full database of indicators for the parliamentary constituencies and local authorities can be accessed here: The Geography of Financial and Economic Vulnerability in England and Wales | Registry Trust

The report analyses vulnerability through the lens of CCJ data as it is both a lagging and leading indicator of financial vulnerability. It is a lagging indicator in that if a person (or small company) has a debt judgment registered against them this can be a clear signal they have been experiencing a debt related problem.[2] The data shines a light on areas with high concentrations of problem debt and financial vulnerability which need to be addressed.

It is a leading indicator in that a CCJ stays on the public Register for six years and can affect ability to obtain affordable credit other services and other opportunities.[3] High concentrations of CCJs in local areas can undermine efforts to build financial inclusion, resilience, and sustainable, shared economic growth across the country.

The Prime Minister wants to see ‘good growth in every postcode’[4] and the Chancellor of the Exchequer hopes to ‘build a more resilient economy.[5] The Government’s Financial Inclusion Strategy seeks to improve financial inclusion and resilience across the country.

These are laudable ambitions. FIC believes that generating national economic resilience and sustainable growth, and promoting financial inclusion, needs a foundation of financial resilience amongst the most economically vulnerable communities and households. This requires targeted, sustained interventions to address existing detriment and mitigate future detriment. Interventions should be guided by timely, relevant data. Understanding which places are struggling and the scale of that struggle is surely a prerequisite for deploying well-resourced, targeted interventions.

[1] Registry Trust is the non-profit which operates the Register of Judgments, Orders, and Fines on behalf of the Ministry of Justice and similar registers in the other UK jurisdictions and Republic of Ireland by agreement with the relevant authorities. Mick McAteer, the lead author of the report, is also Chair of Registry Trust.

[2] NB Of course, many judgments can involve debts incurred from car parking fines which may result from a person forgetting to pay rather inability to pay. Nevertheless, the fact that a judgment may have arisen as a result of a car parking fine can still affect a person’s ability to access credit and other services.

[3] Such as insurance, or renting in private rented sector.  Employers also use CCJ data as part of due diligence procedures so having a CCJ may affect employment prospects.

[4] speech-29-june — Andy Burnham

[5] John Healey says best thing we can offer young people is a first job – BBC News

FIMC has responded to the FCA’s consultation on simplifying the disclosures made to consumers intended to help them understand the impact of costs on their investments. The response can be found here: FIMC submission FCA CP26-24 simplifying consumer investment disclosure final

Understanding the impact of costs is very important. Two things determine the outcome consumers receive from investing. The investment returns and the costs extracted by investment firms (and other firms in the supply chain such as investment platforms and advisers). Good future investment performance cannot be predicted from past performance. But, we do know that the more costs are extracted by investment firms, the more a consumer has to invest to produce the same outcome. It is essential that the FCA drives down investment costs.

We agree with the FCA’s general approach that all ongoing costs should be disclosed. We also agree that the disclosure should be simplified as far as possible as separate rules for different type products just add unnecessary complexity. We also very much agree with the FCA’s general efforts to streamline the rulebook and the principle of combining and consolidating relevant rules for all investment business as long as this does not inadvertently result in losing important consumer protections.

But we disagree with some of the FCA’s detailed proposals. The FCA is allowing investment firms too much discretion on how to disclose costs pre- and post- sale. We have seen real progress in reducing costs in the market for investment products over recent years. However, a number of recent initiatives threaten to reverse that progress.

The FCA’s and TPR’s Value for Money (VFM) agenda will create opportunities for active managers to extract higher costs[1] as will the drive to persuade pension funds and others to invest more in opaque, poorly regulated and governed, risky private assets which offer questionable value. The proposals in CP26/24 will make it difficult for consumers to compare costs, and recognise how much potential value is likely to be extracted through high charges and fees. This is likely to weaken competitive pressures on the market to the disadvantage of consumers. The FCA should be prescriptive on how firms disclose charges and the potential impact of those charges on consumers’ investments.

We strongly disagree with the FCA’s proposals on pensions business. The FCA rightly sees the case for pre-and post- sale consistency around disclosure on investment products. The case for meaningful post-sale disclosure is arguably even stronger with pensions given the central role they play consumers’ long term financial security. If consumers are to make effective, informed decisions about retirement planning they need access to clear information post-sale to keep track of the impact of the value extraction caused by high costs on those retirement plans.

We urge the FCA to treat pension schemes, local authorities, and charities as equivalent to retail clients and provide them with the same protections. The decisions made by trustees and local authority representatives can affect the financial wellbeing of large numbers of individuals. They may well have access to professional advice from consultants and advisers. But, that is all the more reason to ensure they have robust protections given the conflicts of interest in the supply chain when advisers and consultants are involved. The VFM agenda and the push to get institutions such as pension schemes to invest more in private assets increases the risks of poor outcomes.

[1] The VFM initiative will allow investment firms and advisers to elevate the importance of investment performance (even though future performance cannot be predicted from past performance) and distract attention from the importance of charges and fees. FCA/TPR Consultation CP26/1 The Value for Money Framework: Response to consultation, further consultation and discussion paper | The Financial Inclusion Centre

Financial Inclusion and Markets Centre (FIMC) has submitted a response to the PRA’s proposals contained in CP8/26 on funded reinsurance and, specifically, in relation to bulk purchase annuities (BPA) used to transfer valuable defined benefit pension scheme commitments to poorly regulated life insurers who manage the pensions of millions of people in the UK. See: FIMC submission CP8-26 0726 final

We are pleased that the PRA has recognised the significant risks associated with the growth in the use of funded reinsurance and the BPA market. We support the PRA’s intention to better align the regulatory treatment of funded reinsurance with that of economically similar assets in the market.

We are hopeful the proposals in CP8/26, with respect to future pension transfer arrangements, should: i. encourage a more responsible approach to the use of funded reinsurance by insurers; ii. address competitive distortions in the BPA market between insurers that use funded reinsurance and those who do not; and iii. force insurers to adopt a more realistic approach to pricing of BPA deals and cause pension scheme trustees to reconsider transferring pension liabilities to life insurers covered by the weak Solvency UK regime.

But, we do not think the proposals go far enough to mitigate the funded reinsurance risks
related to future arrangements. For future arrangements, rather than aim for a capital
charge of around 10% of liabilities, we argue the PRA should aim for the upper end of the
11-15% range currently applied to economically similar assets.

Moreover, existing arrangements (including those made between now and the cut-off
date of 30/9/2026) will not be covered by the CP8/26 proposals. We appreciate the PRA cannot apply the capital charge measure retrospectively to specific in-force funded reinsurance arrangements due to the disruption this would cause. However, now that the PRA has quite rightly raised major risks associated with funded reinsurance, it surely cannot leave these legacy risks unaddressed. Therefore, we urge the PRA to consider deploying supplementary capital tools to ensure equivalent prudential regulatory treatment of firms which used funded reinsurance for previous BPA arrangements and those who did not.

FIMC has submitted a response to the Access to Banking Services Review: Call for Evidence FIMC access to banking 160726

We were very pleased to see the Review set up as we consider accessible banking services should be treated as a utility service rather than a discretionary consumer service with the market determining which services are provided and how services are provided. Indeed, we would say there is a strong case for treating access to banking as a universal service given their importance not just to consumers, but local economies and communities.

The large scale closure of the bank branch network has affected financially vulnerable consumers and SMEs. Maintaining a comprehensive network of accessible banking services should be a priority for government and the regulators.

FIMC has submitted views on the Second Pensions Commission Interim Report. The submission can be found here: FIMC submission 2nd Pensions Commission 140726

We think the Interim Report provides a very comprehensive and forensic analysis of the challenges the UK faces in building a fair and equitable, adequate, sustainable, and efficient pension system that works better for people currently not well served by the current system.

The work of the First Pensions Commission resulted in one of the few significant public policy successes of recent years through the establishment of autoenrolment (AE) and the NEST pension scheme. Millions of people that were not contributing to a pension are now doing so. NEST and charge caps which limited how much pensions, insurance, and investment firms could extract from people’s pensions introduced some real competition and value into the private pensions market for the first time.

But, as the Second Pensions Commission rightly highlights, conditions have changed since the publication of the First Pensions Commission Report and the foundation provided by those reforms now need to be built on.

If the pensions system is to work for everyone it should be: safe and resilient; sustainable over the long term; fair, equitable, and inclusive; efficient and fit-for-purpose so each £ of taxpayers’ money and pension savings works as hard as possible; and well-regulated and governed so people can have confidence and trust in it. It should address the low levels of pension provision amongst certain financially vulnerable groups.

We have high expectations that the work of the Second Pensions Commission will also result in major achievements given the right political will and effective collaboration between relevant stakeholders.

FIMC has submitted a response to the Financial Conduct Authority (FCA) consultation on reviewing the financial promotions rules for consumer credit. The submission can be found here: FIMC FCA Fin Promotions CP26-15 0626

We cautioned against relying too much on the Consumer Duty and removing some important specific provisions in CONC – the Consumer Credit sourcebook that sets out the FCA’s expectations for firms involved in consumer credit and debt related activities.

We support the proposal to retain the rule in CONC 3.3.1R relating to the clear, fair and not misleading requirement so that the private right of action remains.

We very much welcome the FCA’s measured approach to the annual percentage rate (APR). Further analysis and deliberation is required before any decisions are reached. Our view is that the APR should definitely be retained and supported with additional cost metrics. Moreover, firms should be mandated to inform potential borrowers what rate they are likely to get at the soft search stage.

Financial Inclusion and Markets Centre (FIMC) has responded to TPR’s consultation on its new five year Corporate Strategy. The submission can be found here: FIMC TPR Corporate Strategy 0626

FIMC supports TPR’s overall vision of people having a sustainable income in retirement and the supporting outcomes: Member Outcomes – Savings are secure; Better value; Pensions are fair; and Market outcomes – Well-run schemes; A sustainable and resilient market; A seamless and integrated system

We have a similar vision and outcomes for the pension system. We articulate this as follows: if the pensions system is to work for everyone[1] it should be: safe and resilient; sustainable; fair, equitable, and inclusive; efficient and fit-for-purpose; and well- regulated and governed.

But, the building blocks for such a system are not in place. The scale and nature of the challenge requires combined, concerted efforts on the part of government, all the regulatory authorities, civil society organisations including trades unions, employers, and the financial services industry.

There is much TPR itself can do to ensure the pension system is safe and resilient, well governed and regulated, and delivers better value for money for pension savers.

[1] Not just scheme members but other citizens, the real economy, and the environment.

Financial Inclusion and Markets Centre (FIMC) has recently submitted responses to a number of consultations from the Financial Conduct Authority (FCA, The Pensions Regulator (TPR), and Financial Ombudsman Service (FOS). The main ones are listed below.

Financial Conduct Authority (FCA) Consultation Paper CP26/10 Simplifying the Pensions & Investment Advice Rules

FIMC recently submitted a response to this consultation paper. The submission can be found here: FIMC CP26-10 simplified advice 220526

The proposals on simplified advice cannot be considered in isolation and must be seen in the context of the wider reforms to the market for financial advice and the redress system. In our view, the combined effect of the reforms will be to weaken consumer protection and access to due redress. It is also a missed opportunity for the FCA to use its flagship Consumer Duty initiative to protect consumers and deliver better value for money for consumers.

The Financial Ombudsman Service (FOS) and Financial Conduct Authority (FCA) consultation CP26/9** Modernising the Redress System

FIMC recently submitted a response to this important consultation on reforming the UK financial redress system. The submission can be found here: CP 26-9 FIMC response 110526

We fully support the goals of ensuring that consumer harm is identified and addressed more effectively, and consumers get access to redress more swiftly. We are also very supportive of FOS initiatives to make the redress system more inclusive and accessible. But, we are very concerned about the potential cumulative impact of the proposals in the recent consultations produced by HMT and FCA/FOS. The combined effect of the proposals is likely to weaken consumer protection, risk compromising the independence of FOS, and undermine the ability of consumers to obtain due redress.

Financial Conduct Authority (FCA) Consultation CP26/7 Credit Information Market Study Proposed Approach To Implementing FCA Remedies

FIMC submitted a response to this important consultation on improving the credit information market. The submission can be found here: FIMC submission FCA Consumer Credit Information Final

We very much welcomed the proposals set out in this consultation paper. We are very encouraged that the FCA is endeavouring to improve the information used by the market so as to better promote responsible lending. We agree that the FCA’s proposals on sharing the data specified should help improve creditworthiness assessments and expand access to welfare enhancing credit for many consumers.

We are particularly pleased to see the proposal to introduce a requirement for firms to report county court judgments (CCJs) and decrees as satisfied when they become aware of settlement.

Financial Ombudsman Service (FOS) Consultation 2026/27 Plans and Budget

FIMC recently submitted a response to the FOS consultation on its 2026/27 Plans and Budget. The submission can be found here: FOS plans and budget 26-27 FIMC response 210126

We are very supportive of the role of the FOS. As the consultation says, FOS is a critical part of the regulatory ecosystem. It is important that FOS retains its operational independence and has the necessary resources to fulfil its role. We support the goal of a digital first service. But, we would urge FOS to ensure that the drive for digitalisation does not become a barrier to access to FOS. Retaining access options for consumers who are digitally excluded and/ or are not digitally capable and confident will be important. We would very much welcome further work on awareness of rights amongst different groups of consumers, attitudes of different groups towards dealing with formal redress systems, and the barriers facing consumers with lived experience when engaging with the redress system.

Financial Conduct Authority (FCA)/ The Pensions Regulator (TPR)
Consultation CP26/1** The Value for Money Framework: Response to consultation, further consultation and discussion paper

FIMC submitted a response to the FCA/TPR consultation on the Value for Money Framework. The submission can be found here: FIMC FCA TPR VFM 0326

We support the basic idea of VFM assessments of charges and service quality. The FCA/TPR has clearly put much thought into developing a workable VFM framework. But we are very concerned about the degree of emphasis placed by the FCA/TPR on investment performance, particularly past performance, in the proposed VFM framework. Superior investment performance may well end up offsetting higher costs and charges. However, that cannot be said to be down to predictable ex ante skills on the part of the investment manager, consultants, advisers, and other intermediaries. By allowing past investment performance to be the core of a VFM assessment, the FCA/TPR risks misleading pension savers and distorting the market. We have made significant progress in driving down charges and costs in the UK pensions and investment industry including through the use of the workplace pension charge cap. The weakening of the workplace pension charge cap and now this VFM framework threatens to reverse this progress.

The Financial Inclusion and Markets Centre (FIMC) has published its submission to the Financial Conduct Authority (FCA)/The Pensions Regulator (TPR) recent consultation on a new Value for Money Framework (VFM) for workplace pensions. The submission can be found here: FIMC FCA TPR VFM 0326

As we said in our response to the previous consultation CP24/16, we are supportive of the basic idea of VFM assessments of pension scheme charges and service quality. FCA/TPR have clearly put much thought into developing a workable VFM framework.

But we are very concerned about the degree of emphasis placed by the FCA/TPR on investment performance, particularly past performance, in the proposed VFM framework. Good past investment performance does not predict good future investment performance.

Disconcertingly, FCA/TPR intend to basically allow pension firms to select their own assumptions to project future investment performance. There is no logic to allowing firms to select their own assumptions. The risk of firms trying to game the system is all too obvious. Moreover, worryingly FCA/TPR will not require firms and trustees to publish the assumptions used to project investment returns or to publish the advice received from external advisers so that independent observers can see whether external advice has been ignored.

The VFM framework with its emphasis on investment performance will just allow investment managers, consultants, advisers, and other intermediaries to divert attention from the importance of costs and charges and actively promote and sell high cost, complex investment strategies which actually offer little added value but introduce greater risk. It risks causing more pension assets to be invested in high cost, complex, opaque, poorly regulated and governed ‘alternative’ investment assets and vehicles ssuch as private equity with questionable past performance track records and future prospects.

Giving past investment performance such a key role in a VFM assessment, and allowing firms and scheme arrangements to use their own assumptions about future performance, could give a false and misleading measure of VFM and undermine the integrity and usefulness of any rating system intended for comparison. Overall, we think the proposed framework risks misleading pension savers and distorting the market. It is likely to result in poorer quality and value outcomes for ordinary pension savers and investors, and less efficient allocation of resources by financial markets.

The Financial Inclusion and Markets Centre (FIMC) has submitted a response to the FCA’s important consultation on buy now, pay later (BNPL) lending. BNPL is a source of significant consumer detriment. We support much of what the FCA is proposing. But, we think the regulator is not going far enough to address the harms caused by the inherent design features of BNPL which enable lenders to exploit behavioural biases. Our submission can be found here: FIMC FCA BNPL Sept 25 final