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We expect the current guidance to be in place in some form for the foreseeable future, and although it does not prevent us from doing our job, it does require a change in operating model to protect both us and our clients.

Agents should have risk assessments and method statements in place outlining how contactless vehicle collections are managed. This takes away any anxiety that the customer may have regarding handing back vehicles promptly, particularly regarding end of term collections and Voluntary Termination/Voluntary Surrender cases. To avoid the risk of cross contamination, our agents are signing vehicle condition reports and delivery receipts on our devices rather than customers, however, these are completed in the presence of customers and a copy is automatically emailed from our systems to the customer upon completion for their records, further eliminating any potential reluctance to engage in the process. Standing instructions are to wear a face covering for all customer interactions and a full complement of PPE is carried on all vehicles.

In the case of repossession instructions, agents should be currently attempting to consent these in advance. Automated system SMS, email and telephone contact has provoked a good engagement rate for us within the portfolios utilizing this method. Where customers do not engage, the cases are issued to field agents in the normal way. Standard repossession activity can then take place in accordance with FCA CONC.7, including, where necessary, keyless recoveries if they can be carried out in accordance with the current guidelines, and the case has been referred to management for approval.

Agents do need to bear in mind their clients’ obligations around FCA Prin.6 & 7, to treat customers fairly and communicate clearly. Where a customer is claiming to have been affected by the COVID-19 pandemic, they should be referred back to the client for review. Customers whose arrears are solely as a result of furlough or impaired income during the pandemic, may well recover to their previous payment performance, and are likely to remember the way they were treated during their COVID-19 issues. It is important that agents are mindful of this when attempting repossession. However, we have found customers who did not engage with any attempts at contact, but when visited in the field, were happy to surrender the vehicle, citing that fact that they had no further use for it, proving the theory that field action should continue to be used, particularly in cases where customers are not engaging.

Data gathering around the method of consent received, is already proving to be useful. We are capturing the consent method and comparing across portfolios, to enable us to further hone our contact strategies going forward. Complaint rates should also be monitored, and if the correct processes are followed, should not show any increase.

Agents should be conscious that volumes are likely to spike in the coming months. With this in mind, we are currently investing in additional fleet capacity to ensure that we are ready to deal with this influx of cases. We have this month, taken delivery of a batch of three additional vehicle carriers, with a further batch of three currently in build. Despite this increase in our field capacity, we are continuing to monitor volume trends to ensure that we have the required capacity to service our clients, and are in ongoing contact with our preferred manufacturer regarding delivery lead times to further bolster our fleet if necessary.

We believe that Agents are best placed to create customer engagement, where none has been forthcoming. As long as the correct, compliant and safe procedures are followed, their actions should benefit both lenders and customers alike.