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CONC 7.2 Clear effective and appropriate arrears policies and procedures

Arrears policies


A firm must establish and implement clear, effective and appropriate policies and procedures for:

  1. (1)

    dealing with customers whose accounts fall into arrears;

    [Note: paragraph 7.2 of ILG]

  2. (2)

    the fair and appropriate treatment of customers, who the firm understands or reasonably suspects to be particularly vulnerable.

    [Note: paragraphs 7.2 and 7.2(box) of ILG and 2.2 (box) of DCG]


Customers who have mental health difficulties or mental capacity limitations may fall into the category of particularly vulnerable customers.

[Note: paragraph 2.2 (box) of DCG]


In developing procedures and policies for dealing with customers who may not have the mental capacity to make financial decisions, firms may wish to have regard to the principles outlined in the Money Advice Liaison Group (MALG) Guidelines “Good Practice Awareness Guidelines for Consumers with Mental Health Problems and Debt”.

[Note: paragraph 3.7r (box) of DCG]