Home Credit inquiry - Main party submissionDocument Transcript
S & U PLC
REPRESENTATIONS TO THE COMPETITION COMMISSION RE: INVESTIGATION INTO
THE HOME CREDIT INDUSTRY
S&U PLC makes this submission to the Competition Commission following the reference to it
by the OFT of the Home Credit Industry for investigation under section 131 of the Enterprise
Act 2002. This follows a complaint against the industry by the National Consumer Council
under the same Act last year.
As we made clear to the OFT, we argue that there are in reality no factors, or combination of
factors, of the market for home credit in the UK which restrict, prevent or distort competition
so as to harm the interests of our customers. We therefore feel that the OFT reference to
you was misguided, disproportionate and unnecessary. Indeed we regard it as highly
unsatisfactory that, in contrast to its position on merger references to the Competition
Commission, the OFT has not published until well after the opening of this investigation by
the Commission, its reasons justifying the reference.
In any event, upon reading the OFT's reasons, it emerges that they consist in large measure
of a rehash of the allegations made to it by the NCC, in consequence of which the OFT
assumes that there may be a case to answer without adducing any specific evidence for
this, particularly in the field of product price and profitability. We are therefore somewhat
sceptical as to the extent to which the OFT actually took consultation with the home credit
industry into account when making this reference.
We therefore contend that the OFT has wrongly based its conclusions on
• a mis-understanding of the relationship between customers and lenders;
• ignorance of the principal aspects of the home credit service (including price) which
customers take into account when selecting a lender;
• a failure to understand how industry practices, such as step-up and roll-over loans
actually protect and in many cases are initiated by customers;
• a failure to acknowledge that customer satisfaction derives not from ignorance or
dependence upon lenders but from a rational and careful comparison of competing
products and levels of service;
• a failure accurately to interpret the structure of the market and the movement of
lenders in and out of it in response to competition; and
• an artificial constraint on the definition of the relevant market in which home
collected companies operate so as to discount significant competitive pressures
from outside the sector.
We deal as succinctly as possible with these six areas below. They broadly reflect topics
raised by the OFT in its December 2004 document “The OFT Reasons for Making a
Reference to the Competition Commission”.
We were advised at our preliminary meeting on the 17 January, to respond
comprehensively to the OFT’s main contentions on anti-competitive practices whilst avoiding
unnecessary duplication of earlier submissions to the OFT. We therefore decided that this
submission would specifically take account of our response to the OFT of the 18 October
during the previous pre-reference consultation. This accompanies the submission as
Appendix 1. In addition we have, at Appendix 2, enclosed a copy of a briefer response we
made to the OFT in July last year when we met them during the original consultations on the
We have not included our original response to the OFT’s questionnaire of last summer
although we can do so if this would be helpful. Neither have we provided the Competition
Commission with significant primary evidence at this stage since no doubt the Commission
will be making further inquiries regarding this, both from S & U PLC and the industry more
widely. Finally, since this submission responds to the OFT’s reasons for the reference paper
we have indicated the relevant paragraphs in brackets throughout our text.
The home credit finance industry has operated in almost exactly the same way for the past
30 years at least. Prior to this, as the CCA have explained to you, many companies including
S&U offered goods on credit paid for by a weekly collected visit. This business has operated
nationally for over a 100 years; S&U itself opened for business in 1938.
Whilst IT systems have become more sophisticated and allowed better customer analysis
and, to a limited extent, faster reporting from agents, loan products themselves have
changed remarkably little. Equally important, the type of average customer, the real value of
balances owed by customers and the basic relationship between home collected agents and
their customers have remained stable over three decades.
It is true that many traditional home collected customers have migrated, both geographically
and to more “sophisticated” (meaning generally longer term and more remote) loan products.
It is also true that certain methods of payment, particularly by cheque and to a lesser extent
by debit card, have become more widespread. Nevertheless, the basic relationship between
home credit customers and lenders which even the National Consumer Council and the OFT
have acknowledged as flexible, forgiving, informal and convenient has remained. Home
collected companies still provide a weekly, customised, collection service for each customer.
They still operate on a fixed charge basis irrespective of how long the customer actually
takes to repay their loan, without adding any additional loan interest or other charges. This
stability has elicited very high levels of customer satisfaction. Indeed Professor Elaine
Kempson, the distinguished consumer credit expert from Bristol University, found precisely
these “high levels of [customer] satisfaction with the quality of service” in her survey of home
credit for the DTI in 2002 as she had in 1989.
What has undoubtedly changed is the economic and political climate in which the home
credit industry has to operate. The growth in other consumer credit products, though not in
home credit, has been exponential. Mortgage backed and credit card debt has rocketed,
boosted recently by post tax incomes that have risen nationally from £488 billion to £700
billion in real terms between 1989 and 2002. As a result consumer debt generally has risen
to £1 trillion for the first time, a fact which has attracted unfavourable comment in the media.
Yet, as Professor Kempson points out in 2002, the more mundane reality is that the vast
majority of households actually use credit wisely, are unburdened by it and find that it can
substantially enhance their standard of living. Moreover, it is plain that this is a boom which
has passed the home credit sector, as opposed to other forms of consumer credit,
emphatically by. Evidence of this is provided by the National Association of Citizens Advice
Bureaux in their 2003 Report “ In too Deep” and by Datamonitor research carried out during
the same period. This showed that home credit only accounts for 4% of total consumer debt
and that it has grown between 1978–2002 at less than half the rate of unsecured personal
loans generally and only at a quarter of the rate of credit cards. Indeed evidence since 1992
shows that this relatively slow growth has become contraction. Provident Financial recently
announced that they anticipated that the UK home credit sector was likely to contract by
1.7% a year for the next 10 years. The number of members of the Consumer Credit
Association has been declining for the past decade. Previously large players like Morses
(swallowed by London & Scottish last year), Cattles, for whom home credit now only
accounts for 12% of its business and London & Scottish themselves have all exited or
significantly reduced their reliance on the home credit sector.
The regulatory climate surrounding the industry has changed too. An understandable
emphasis on "financial inclusion" and consumer protection, which S&U supports, has led to
a more detailed intervention in the sector. Yet for the vast majority o consumers, the
expansion of credit has led to significant improvements in their standard of living.
Unfortunately, certain lobby groups, like the NCC, have placed undue and disproportionate
emphasis on the problems of a very small proportion of consumers as justification for even
Yet in recent years there has been significant regulation and investigation into this segment
of which the current inquiry is the latest manifestation. For example:
• the reform of the Consumer Credit Act;
• new Advertising and Early Settlement Regulations;
• a proposal for a new European Consumer Credit Directive;
• the "Overindebtedness Task Force";
• Treasury Reviews on Interest Rate Ceilings; and
• Consumer Credit Education Initiatives.
These have all impacted upon consumer credit generally and hence upon home credit. Yet it
is precisely the home credit sector that has not been responsible for, or indeed profited from,
the credit boom which appears to have a significant motivating factor for these
Far from being oppressive of its customers, home collected credit sector enjoys almost
unique levels of customer satisfaction within the finance industry. MORI conducted surveys
for both the OFT and the industry on this point and found levels of satisfaction which were
above 80% for all customers and indeed showed 66% approval rating for value for money.
Professor Kempson confirmed this very high level of satisfaction and indeed the OFT
themselves were forced to admit “high levels of satisfaction with the quality of the [home
S&U is proud of the weekly service its, often female, agents provide to customers. Although
it appears to be an expensive method of managing credit accounts, our experience is that
customers both enjoy and value the personal contact that this brings.
We understand that the Consumer Credit Association have used the Freedom of Information
Act to ask the OFT how many complaints they have received about the sector in the last 10
years. We anticipate that the level of complaints regarding home credit will be very low. This
is partly confirmed by CAB statistics recently studied by the Department of Trade & Industry
as part of the Regulatory Impact Assessment on the Consumer Credit Bill. CAB statistics on
consumer credit enquiries was overstated. A further proportion of this reduced number of
enquiries related to balance enquiries or access to credit rather than complaints about it.
In a rational world therefore it would be reasonable to assume that the industry would be
allowed to continue to offer the same high value of service to its customers as it always has.
The fact that it lacks this luxury is almost entirely due to activities of a very small, inter-
connected and determined group of politically motivated campaigners whose basic aim is to
achieve the demise of the industry.
As the Director of the CCA, John Lamidey, pointed out to you recently, a small number of
activists use organisations such as Church Action on Poverty, Money Advice Centres,
positions as Trading Standards Officers, campaign organisations such as Debt on the
Doorstep and academic ones like the new Economics Foundation, to influence semi-
statutory bodies like the National Consumer Council.
In this context, it is extremely disappointing that the OFT seems uncritically to have accepted
the assertions made by the NCC in its (similarly worded) January 2005 reasons paper.
A Competitive Market
When it investigates whether the UK home credit sector has features which prevent or distort
competition, the Competition Commission will no doubt consider how a competitive market
might properly be defined. We have reservations about the OFT’s definition of the size of
such a product market which we set out below.
In our view, a competitive market is one where customers are able to choose between
products or services offered by suppliers who vie for their custom at different levels of
service and price and who are forced to take account of such competition when designing
their products or setting their prices. An effective process depends upon customers being
able to purchase from alternative suppliers (even though they may not always do so) and
that the structure of the market is such as to allow new products and new suppliers to enter it
in response to customer demand. We contend that the home credit market fully reflects
Contrary to the OFT's assertion, there is ample evidence of both demand and supply-side
substitution in the home collected credit sector. Below we answer the specific arguments put
forward by the OFT to allege restricted competition within the sector.
1. The Real Bargaining Position of Customers
Home collected lenders are extremely benign and supportive of their customers. Flexibility is
the basis of their offering. We do not impose penalties for late payment thus giving
customers security, certainty and stability as to their total commitments. [Confidential].
Customers are allowed extended payment periods without any penalty and, provided
recent repayment history confirms their ability to make future repayments, customers are still
allowed further loans.
Customers develop close relationships with our agents. Such relationships only properly
develop over the long term and therefore it is in the agent’s interest to ensure that his
collection of home credit repayments is sufficiently flexible to accommodate any temporary
financial difficulties that our typical C2,D,E customers inevitably encounter. This is plainly a
matter of common sense for the lender but also results from the customers increasingly
strong bargaining position.
For very small loans the costs of court action to recover debt nearly always outweigh the
benefits. Courts are reluctant to order any more than nominal repayments, especially given
the information presented to them by customers which often varies substantially with that
they volunteered when contracting the loan. As a result court judgements for debt have
generally fallen from 2.2 million actions in 1991 to less than a million by 2000 and much
further since. In the unsecured small loans market they are rarer still. [Confidential].
Customers are aware of this. They regularly avail themselves of the advice of CABs, money
advisors and, increasingly, commercial debt consolidators all of whom offer the prospect of
repayments very well below terms and usually well below the customer’s real capacity.
Moreover, customers are aware that agents know that, in a majority of houses, lenders face
competition from other home collected firms. From S&U’s own experience, we found the
OFT’s conclusion that home collected companies did not face such competition totally
In short, customers do not need to “switch” lenders to take advantage of competition
[Confidential]. Lack of switching is not evidence of lack of competition. The OFT dismissed
this very important feature of the home collected sector in just one paragraph (77). They
cited a lender who offered this argument as “not, however, providing evidence to support this
assertion”. But such evidence is inevitably difficult to provide. First a lender would require
access to a competitor’s books to see the extent to which the customer took advantage of
alternative loan offers. Second, the threat from the customer is often enough – the agent
allows lower repayments or has to grant a further loan.
Although possibly designed as an attack on the home collected industry, the recent BBC 2
programme “Drowning in Debt” actually emphasised the bargaining power of customers,
particularly in relation to home collected lenders. It was very significant that the couple’s only
home collected lender, Provident Financial, was not only taking reduced terms on the loan
that they had provided, but on both occasions when they called during the programme
meekly accepted a refusal to pay. This is hardly evidence (57) for the OFT’s argument that
“the nature of the relationship between collectors and customers creates a feeling of
obligation on the part of customers to those who collect repayments from them”.
2. Price and Price Comparisons
Although framed by the OFT (17) as being concerned that customers have difficulty in
comparing loans between lenders, the reality of their complaint (made explicit by the NCC) is
apparently high price. The inference is that since APRs are high, customers cannot be
getting good value. This is either because they are not making comparisons with “better
value products” (both within and outside the HCC sector) or because they are in a poor
bargaining position. We have just responded to the last point; the earlier ones are covered in
Appendix 1 but we add the following. The APR is a totally misleading measurement of price
for short-term loans. It is even more so for short term collected loans, since all direct
collected costs must be included in the APR. This contrasts with the AER quotable by
clearing banks who are allowed to exclude their servicing costs from this figure.
At a recent Institute of Economic Affairs Conference, the Chief Executive of Provident
Financial, Robin Ashton, argued that clearing banks charge as much for a short-term £300
unsecured loan as do home credit companies who actually provide an additional weekly
collection service. They do so yet only have to quote an AER around a tenth of the home
collected companies’ APR!
Included in our pack to the Competition Commission is a paper by Hardiman which attempts
to show the effective APR for home credit when administrative and collection costs together
with the real rate of repayment is calculated. This is a powerful argument against the notion,
put forward by the OFT, that prices for home collected products are unjustifiably high.
S&U now understands that the Competition Commission are to receive a delegation from the
CCA specifically to discuss how the APR calculation distorts and exaggerates the cost of
borrowing over shorter term.
The Government themselves have recognised the limitations of APR as a measure but
appear to have been unable to devise an alternative method when framing their Consumer
APRs are an even more misleading measurement of comparative value when applied in the
home collected industry. The OFT (41 and 42) insist that competition is evidenced (a) by
price comparisons and (b) by customer switching. We deal with the latter further on. The
OFT do concede (45) that price may not be the only way in which customers choose
between different lenders. Other factors affecting the service the customers get from their
agent include friendliness, reliability, understanding on repayment terms, convenience etc.
But the OFT persist that because these factors are difficult to measure; working class
customers cannot be making rational decisions on price and service; this, it is alleged,
reduces the incentive for loan providers to compete.
We dispute this. It is totally condescending to assume that home collected customers cannot
make buying decisions based upon price and service, just as middle class customers decide
when comparing the value of holidays, cars or insurance policies. The fact that home
collected customers may so value the service that they are prepared to countenance high
nominal APRs, artificially inflated by collection costs and disproportionately influenced by
short-term repayment periods, is not evidence of either their ignorance, or of a “weak
bargaining position” or of lack of competition.
The OFT speculates and expresses (48) a general concern “about the extent of customers’
difficulties” in comparing different home collected lenders. They offer three unsupported
• First, that because APR’s (48) are neither a good comparator between home
collected finance and bank loans nor a ”good measure in the home collected
market”, customers must be misled about them and therefore be unable to compare
different home collected loans. The remedy is surely to construct a measure that is a
good comparator rather than arbitrarily assume its absence means an
uncompetitive or restricted home collected sector.
• Second, even ignoring APR the OFT (47) alleges that customers find it difficult to
compare different home collected loans (on total cost, loan terms and size of weekly
payment) because there is “no standardisation of loan terms between lenders”. Yet
the home credit industry is almost unique in the plain presentation of its loan
advertising material, as amended and made plainer still by the new Advertising
Regulations which took effect in October last year. You have a copy of our own loan
advertising. Further in what field does the OFT argue that there is such
standardisation of terms? Is the unit trust or life assurance market automatically
assumed non-competitive merely because it offers varied, flexible and even
customer specific products? Are BMW and Mercedes only to be assumed as
competing if they provide vehicles of identical specifications?
• Third, the OFT insist (like the NCC) that high APRs mean high prices. High prices
must be a sign of high margins, “substantial profits” and therefore a lack of
competition. Nowhere do they attempt to justify any of these claims. High APRs,
they admit, result primarily from the method of calculation for short-term loans not
from high interest charges. Indeed, the paper by Hardiman mentioned above argues
that interest rates in the home collected field are comparable to or less than those of
credit cards (and other relatively high risk unsecured credit products) if real
repayment periods and collecting costs are taken into account.
Nor, in terms of gross margin or company profits, can home collected prices be regarded as
high. Whilst the OFT (80) lamely state that “the limited analysis of profitability which you
have carried out indicates, that at least some lenders appear to be making substantial
profits” [our italics], the more recent Lexecon Survey produced by the industry in 2003/2004
(a copy of which is attached at Appendix 3) produced different findings. Gross margins were
not high particularly compared to the retail market.
Return on capital for the industry was not excessive particularly since it represented many
years of accumulated investment. Charges for credit granted, at around one half the
principal over a 6 month term were remarkably similar throughout the world. If home
collected yields “substantial” profits which derive from restricted competition, then the OFT
fails to explain why leading players like Cattles, Morses and London & Scottish are gradually
exiting a supposedly hugely lucrative and exploitative industry.
3. Misunderstandings on Switching
We earlier argued that a perceived “lack of switching” as a feature of customer conduct was
not evidence of a lack of competition. Customers, if satisfied, value a combination of service
and price which makes the uncertainties inherent in switching, even to apparently lower cost
products, a powerful disincentive. This does not mean that customers are unaware of prices
elsewhere in the home collected sector, or further afield. Few would argue that middle class
savers or borrowers would be acting rationally in continuously juggling between clearing
banks or building societies dependent upon their weekly savings or mortgage rates.
Yet the OFT dismisses (72) the notion that lenders therefore have to compete on both price
and service by citing lack of “sufficient evidence to enable us to test lenders assertion that
they compete on the service elements”. If the Competition Commission study lenders’ books
this will be confirmed.
Of course, longer serving Representatives do have larger books: their reputation for good
and flexible service does give them new and recommended customers. Representatives
who respond sensibly to the financial difficulties of their customers generally gain better
payments in the long term as a result. The OFT might perversely try to characterise this as
“customer capture”; customers on the other hand would argue that staying with their
Representatives (a lack of switching) is a rational judgement based on service as well as
The features of customer judgement do not imply, as the OFT argues (74 and 75) that
lenders make no attempt to persuade customers to switch away from competitors. Lenders
do attempt to identify good potential customers; they know that the previous payment record,
as opposed to socio-economic classification, is invariably the best guide to a customer’s
future reliability. Knowledge of such prior payment, often gained through the defection of a
competitor’s agent is a crucial tool home lenders use (within the statutory constraints on loan
canvassing) to persuade customers to “switch” to them.
Obviously the most significant “switch” would involve a new lender so consolidating the
customer’s entire debts as to become its exclusive new source of finance. [Confidential].
Needless to say, as with any market entry, such a strategy does involve commercial risks,
which may be why (74) the OFT thought it not widespread throughout the sector.
Consolidating debts generally involves large sums increasing potential loss. Neither can
there be any guarantee that new customers actually pay off previous lenders or that they
might be invited by the customer to return.
Thus it is not surprising that some lenders state that they do actually see the risk of their
customers switching elsewhere as a significant competitive constraint. This is confirmed by
the contracts most insist upon to prevent Representatives using knowledge of customers to
defect and switch their accounts to other lenders. Far from regarding this as anti-competitive
the courts have generally upheld, for a limited period of up to [Confidential] the ability of
lenders to thereby protect the confidentiality and goodwill associated with our relationship
with customers, in exactly the same way as other industries protect marketing or technical
information. This recognises that “switching” is a threat and that home credit companies are
entitled to temporary relief from it. It does not imply the customers are not fully entitled to
take their payment records to new lenders to obtain better terms for a loan. It simply restricts
Representatives from using their knowledge of such records to steer customers to new
lenders irrespective of the value inherent in doing so.
4. Roll-over and Step-up Loans
Step-up loans are regarded by the OFT as “tending to tie customers into their existing
lender” (53). To the extent that responsible and sustainable lending, particularly in home
credit, is based upon relationships of trust, both lenders and customers will wish to limit their
initial involvement with each other until such trust evolves. Thus, within limits, existing
lenders do enjoy a non price advantage because switching even to apparently lower price
products at higher loans levels, does risk uncertainty, misunderstanding and possible
unanticipated changes to price and conditions. Therefore smaller initial loans, irrespective of
previous payment record with other lenders, is simply a responsible reflection of this.
It is ironic that the OFT seems reluctant to accept this phenomenon in the home credit field,
whilst it criticises credit card lenders for precisely the opposite – i.e. offering high value “low
price” but limited period cards to encourage switching by new customers! This kind of “non
step-up loan” can rightly be criticised because it encourages new borrowing (often on a “net”
rather than replacement basis) without an adequate investigation of whether a customer is
able to repay a larger loan often over a longer term. Step-up loans in home credit on the
other hand are designed precisely so that a customer’s ability to repay can be gradually
confirmed, thus safeguarding both their interest and that of the lender.
Roll-over loans are a feature of home credit because they increase the frequency with which
customers can access finance without either increasing the level of their weekly payment
(through extra loans) nor by imposing upon them longer term or higher levels of debt.
Nevertheless roll-over loans do tend to limit loan account numbers and thus enable better
management of debt. Second, as we argued earlier, they are often the result of customer
expectation and not Representative suggestion. This is why refinancing through roll-over
loans reaches a peak period of demand at Christmas, Easter and during the summer holiday
5. Market Structure, Definition and Barriers to Entry
In our view the OFT has artificially confined its investigation to the home credit sector, by
ignoring the evidence that consumers regard other related credit products as substitutes for
home credit. These products include those detailed in paragraph 24 and in particular
monthly paid direct debit personal loans, overdrafts and credit cards. By so restricting its
market definition the OFT has given the false idea that the sector is oligopolistic, that prices
can be charged above competitive levels, and that it is subject to barriers to entry which
restrict competition and thereby cause customer detriment.
On demand-side substitution the OFT (27) concluded that although home collected lenders
profess to face competition since their home collected customers also had credit and store
cards, they failed to establish that “customers substitute between those types of lending and
home credit, rather than using them as a complimentary source of credit”. The OFT therefore
appears to be arguing that, irrespective of the acknowledged spread of other financial
products to home credit customers, so long as those customers remain, at least partly, in
home credit, no effective competition with other non home credit lenders can be proved.
Definition of the market can therefore be restricted purely to home credit.
In our view, this argument is plainly incorrect. Together with the population as a whole, home
credit customers have enjoyed access to a variety of financial products (as it appears the
OFT now recognises) with which home credit must inevitably compete.
The evidence for this is the fact, of which the OFT was aware, that this competition is
already beginning to bite and that home credit has to an extent suffered from it.
Our customers are continually solicited by mail with offers from credit card and personal loan
companies. These offers often involve high and open-ended interest charges from which
home credit customers are protected.
Earlier we referred to the relative lack of growth of home credit compared to credit cards
and other forms of lending. This is partly the result of a relatively slow pace of growth in
home credit amongst its existing customer base compared to other products; it was also
due to a significant migration of former home credit customers to other forms of borrowing.
Such actual evidence of substitution is the most compelling possible illustration that the
home credit sector forms part of a wider small finance market and that, contrary to the OFT's
assertion, it is subject to strong competitive constraints.
For example, Cattles and London & Scottish have based their recent corporate strategies on
encouraging this trend; home credit customers are incentivised to become direct debit
monthly collected customers with larger and longer term loans. If home credit was not
susceptible to this kind of demand-side substitution then such a strategy would have been
fruitless. Instead Cattles estimate that less than 15% of their business transacted in future
will be carried out through home credit.
Given the consequent decline in the size of the home credit sector in the UK it is not
surprising that the OFT (35) should be aware of “at least 1 CCA member who has ceased
weekly cash collections entirely”. But a contracting sector implies more rather than less
competition. As lenders compete for a reduced number of customers both gross and net
margins are likely to be under pressure. Even then new suppliers will be attracted into the
market - often to take advantage of the gaps left by those leaving it. Park Credit, nationally,
and Loans at Home, regionally, are recent examples.
Contrary to the NCC’s original contention these new entrants have not faced significant
barriers, a point which the OFT has now belatedly recognised. Barriers through regulation
are low although this may change depending upon how the OFT administers the new
licensing regime envisaged in the Consumer Credit Bill. The OFT states (68) that “entry on a
small scale is feasible” and that “barriers to entry are lower than in many other markets”. Yet
despite this and recognising that the sector still boasts a large number of lenders, the OFT
persists in its suspicion that “competition, and in particular price competition, is restricted by
the [my italics] aspects of the market discussed above”. Yet the OFT failed to specify those
aspects which they find responsible. As in much of the rest of the document they rely merely
As a result of the initiatives outlined earlier the home credit industry already faces significant
changes in the way that it operates, and is overseen by regulators, over the next 10 years.
The industry has an excellent record of customer satisfaction, receives a low level of
complaints and is gently contracting. It provides a useful and flexible source of finance for a
part of the population who increasingly see it as complementary to their other financial
activities rather than their sole source of borrowing.
Although these factors undoubtedly act as a constraint upon prices within home credit, they
also force home credit lenders to compete by paying more attention to customer
service.[Confidential]. This has made and continues to make home credit distinct from, and
able to compete with, other forms of consumer finance.
We therefore feel that it would be in the best interests of our customers, and not merely
home credit lenders, if the Competition Commission concluded that the industry should be
allowed to bed down the new regulatory initiatives under which it will operate for at least a
year. During this period we will be prepared to discuss, if necessary, with the Competition
Commission ideas for any lender conduct or features of the market which might restrict
competition in the future but which we now cannot frankly envisage.
Finally, it will be obvious that S&U looks forward to extending every co-operation to the
Competition Commission in what we fully anticipate will be a rigorous and fair review of the
Home Credit sector.
25th January 2005