Written evidence submitted by the Credit
Services Association (CSA)
1. The Credit Services Association (CSA) is the
only national association in the UK for businesses specialising
in debt recovery, tracing and related services. It also incorporates
the Debt Buyers & Sellers Group (DBSG), with members ranging
from high street banks to credit reference agencies and debt buyers.
Our aim is to continually develop and uphold the highest professional
standards across the credit industry.
2. The CSA is in favour of Individual Electoral
3. Clause 1 does provide an appropriate legislative
basis for introducing IER.
4. The proposed clause 1(2)(b) does provide for
flexibility for any application to be made in any manner that
is pre-scribed. The flexibility is dependent upon the appropriate
authority remaining abreast of technology and making the order
pre-scribing the acceptable manner of the application.
5. The verification of the address should in
our view form part of the registration process. We think this
is an opportunity to create an accurate record for the electoral
system and the address information should be confirmed by the
individual until such times that other means are available.
6. In line with a desire to see a robust and
accurate system, we believe that the confirmation of individual
nationality would enhance the accuracy of such
a system. As such we are sceptical as to whether or not the current
system is sufficient; hence we welcome any proposal that improves
7. It is unlikely, in our view, that the system
will be perfect from day one. Consequently we believe that it
is sensible to begin the transition to IER sooner rather than
later. This would allow any flaws in the system to be addressed
prior to the General Election in 2015.
8. We believe that the proposed approach will
lead to a reduction in financial crime, in particular fraud. In
our view any proposal that will result in a reduction of financial
crime is to be welcomed. Therefore we believe that additional
thought should be given to the non-mandatory approach. We accept
that individuals may decline to provide additional information
as there appears to be a reluctance to provide information to
the state. This might be overcome if the provision of this information
were to be compulsory.
9. Research from the Electoral Commission has
found that appearing on the register was popular where it could
be demonstrated that this assisted with the prevention of ID fraud.
This is clearly relevant when the registers are used by the credit
reference agencies in the granting of credit to individuals. There
is an argument that because not all financial crime occurs at
point where credit is granted, but during the lifecycle of a credit
agreement, use of the register should be permitted throughout
the lifetime of the agreement. This would reduce the amount of
bad debt within the economy and should ultimately reduce costs.