[Magdalena]

Good afternoon,

To strengthen ABCUL’s response to the Financial Ombudsman consultation, I would urge credit unions to also submit their own detailed response.

We need to consider the real implications of the proposal, such as:

– Compromising the fairness of the complaint process by introducing case stage fees which could promote a complaints culture, especially with easy access to AI-generated complaints.

– Case stage fees could pressure early settlement, even when legally incorrect (example: complaint PNX-5381058-D4L7).

– Individual case fees should be calculated from complaint acceptance, not closure, to avoid paying for FOS backlog.

– Indicative monetary allowance of £2,000 – Disagree that professional representatives should get same allowance as businesses. They often submit large volumes of paperwork strategically to overwhelm firms. Charging them per case encourages careful consideration of complaint merit.

– Quarterly billing in advance for high-volume firms – Not in favour; paying based on predictions can create unfair financial burden, especially during spikes from third-party claims.

– Reducing dispute time limit to six months with quarterly billing – Acceptable, but FOS complaint resolution times should also be reviewed to ensure alignment and fairness.

Northern Community Bank is going to submit our response, however if anyone would like to see it, please email me on Magdalena@northerncb.uk

Magdalena Niemczyk – Head of Compliance and Training – Northern Community Bank

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Simon Haslam; Chair Derbyshire Community Bank

[Magdalena]

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