Putting customers at the heart of regulation



Through innovative data triangulation we shed new light on the consumer experience of high-cost credit products – giving the FCA the richness and robustness needed to have confidence as it introduced tougher regulations on payday loans and other products.


Winner, MRS Financial Services Research Award, 2014


As it prepared to assume responsibility for the regulation of consumer credit, the FCA needed high-quality consumer insight to command the attention of policy and regulatory specialists, wider industry stakeholders (e.g. HM Treasury), and the credit industry at large.

We were commissioned to study the consumer experience of payday loans, logbook loans and paid-for debt management plans.

Recognising the inadequacy of focusing only on participant testimony – particularly in relation to complex products that are poorly understood by users – we employed validation and triangulation techniques to generate robust behavioural insight.

This allowed us not only to verify self-reported data but also understand exactly how and why decisions had been made – including the potential for and level of detriment associated with different choices.

The multi-sourced findings spoke authoritatively to the FCA and its audiences, precisely identifying instances of unfair provider behaviour and current regulatory shortcomings – including examples of how both customers and firms were circumventing measures designed to protect consumers from harm.

The study reinforced the FCA’s confidence as it introduced its robust new regulatory standards to the high-cost short term credit sector, while also providing enduring insight into a hitherto unfamiliar group of consumers.