Memorandum submitted by AdviceUK
Whilst I would be first to agree that all lenders
should be obliged to register both "white" and "black"
data about all their customers (this of course does not mean that
lenders will use that information before deciding to lend) I would
also argue that in order to ensure that lenders can make the best
possible lending decisions they should have access to more information
than they currently do. This would include details such as potential
customers magistrate's court fines, student loans, Tax/NI and
VAT arrears and the automatic registration with credit reference
agencies of housing association or Local authority rent arrears
and council tax arrears etc.
In my view the only way to focus lenders' minds
on affordability is to say (as was proposed in the EC Consumer
Credit Directive and opposed by the DTI/Govt) that debts are not
legally enforceable, and will be remitted, if the agreement was
manifestly beyond the means of the individual at the point when
they took it out.
20 October 2004
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