32
Rejected
We asked if there were lessons particularly for the Department about promoting these products that...
Conclusion
We asked if there were lessons particularly for the Department about promoting these products that have no FCA imprint. An employee on a low salary might decide to take some early advance and it is not actually a regulated product at all. There may be other less advantageous loan schemes, but they will have some regulation. The Department agreed that it was certainly worth noting that the National Audit Office reported that when trusts go into these schemes, it is very frequently to give their employees options that are not much more expensive loans. The Department told the Committee that there is expectation that NHS trusts, in considering these schemes take all information into account.33 32 Qq 158–159, 162; C&AG’s Report, para 3.14 33 Q 203 18 The pharmacy early payment and salary advance schemes in the NHS
Government Response Summary
The government rejects regulating salary advance schemes, stating they generally fall outside credit regulation, show no substantive consumer detriment, and thus do not merit regulation. It welcomes an industry code of practice and will monitor for future consumer detriment.
Government Response
Rejected
Government Response
Rejected
HM Government
Rejected
5.1 The government disagrees with the Committee’s recommendation 5.2 Unsecured consumer credit is regulated under a legislative framework. Where consumer detriment is identified, the government is able to extend the perimeter of that framework to ensure that there is appropriate consumer protection. For example, the government is currently looking to extend regulation to cover interest-free credit agreements under 12 months and repayable in 12 or fewer payments. However, salary advance schemes generally operate entirely outside of credit regulation as the early payment of accrued wages does not usually involve the provision of credit. The government has also not seen substantive evidence of consumer detriment arising from the use of salary advance schemes. It has instead observed that these schemes can provide a useful tool to help people manage their finances, for example meeting unexpected costs or helping to manage the payment of larger one-off purchases. The government’s assessment is therefore that these schemes do not merit regulation, which would impose costs on the providers and would likely be reflected in the costs to consumers. 5.3 The government understands that firms offering salary advance schemes are developing an industry code of practice. The government welcomes this development and, alongside the FCA, is engaging with the industry as the code develops and will consider if any further interventions are needed in the event of any signs of consumer detriment.
Source
Committee
Public Accounts Committee
Inquiry
NHS supply chain finance
Report
Thirty-Fifth Report - The pharmacy early payment and salary advance schemes in the NHS
04 Feb 2022
HC 745
Addressee Bodies
HM Treasury
Timeline
Recommendation age
4.5 yrs
Report published
04 Feb 2022