Memorandum submitted by Mr Malcolm Hurlston
Founder and Chairman of Consumer Credit Counselling
Service (CCCS), Britain's largest debt-advice charity. It currently
manages around a 10th of UK problem debt. CCCS maintains an industry
leading database on people in debt.
Chairman of Registry Trust Ltd, a not-for-profit
organisation which maintains the register of Judgments Orders
and Fines on behalf of the Lord Chancellor. Chairman of Hurlstons,
which devised the original principles of reciprocity for the sharing
of data among lenders.
1. Most of these comments relate to the
credit industry where I have a large amount of experience and
2. Despite calls from the banking/credit
industry for more data to be shared no amount of data sharing
will help in at least half of the cases seen at CCCS. Debt is
mainly caused by life problems.
3. Some banks currently do not share across
their total portfolios, let alone among themselves. Recently merged
banking groups can still operate as completely separate entities
with little communication between them. If there were a convincing
case for data sharing they would have taken speedy steps to share
4. Previously my consultancy provided some
of the expertise which came up with the principles of SCOR.
Representing SCOR I argued to the government at the time that
the industry would not need more data in the future. Work on predictiveness
would mean that inefficiencies could be avoided and that the data
would in effect be better used than in the past.
5. In the United States data is routinely
shared among lenders. The absence of a paper about this from the
protagonists of data sharing in the UK indicates the case for
its effectiveness in the world's largest credit market may be
6. Data sharing is promoted by the credit
industry more generally as the cure for over-indebtedness. However,
as I have attempted to prove above, the case has not been made.
7. This paper is submitted in a personal
245 Steering Committee on Reciprocity. Back