I am still trying to get my head around this whole consumer credit licence thing. I may try and get proper advice just so I know one way or the other. I have already paid their extortionate fee to renew, but who knows? I may be able to get a refund.
We have several ways we provide stuff to consumers, and I am not even 100% sure what counts as "credit" for a lot of what we do.
e.g. The typical broadband consumer pays the same every month, invoiced on the 1st and direct debited on the 1st or immediately after. The invoice is for that month, and so the payment is at the same time as we start providing the service - no "time to pay" and nothing on credit. Well, maybe if the 1st is on a Saturday and DD on Monday, but the way banks work mean the non banking days count as next banking day - so we see the money on 1st or in fact the night before at the latest. So not on credit!
Not all consumers work like that, but most could. Those that don't want 1st for DDs could be billed on a different phase in the month but still not on credit. But I am still not sure what counts as credit in this case. The way we normally work is that we don't expect to be paid until we raise the invoice. This means, if we invoiced, say, 14 days before the start of the month, or a month in advance, or even a month later, we would consider we are owed for that invoice from when we raise it. Some of those options may count as credit in the law, and some may not.
But what if we did invoiced later? Is the 5 working day time to advise a DD (we work on 5 working days not 10, as is allowed under DD rules, believe it or not) counted as credit? What if (like the regular monthly bills) we advised a DD and arranged for the DD to come out on the same day as the actual invoice. That means no "time to pay" from our point of view - not delay between invoice date and payment? Or is that not what credit means.
We do have a couple of snags. We supply routers, though normally that is free with the service, so no credit. Even so, we could arrange the invoice and DD to coincide. For new installs and even chargable routers and kit, we could ask the customer to agree a 2 working day collection by DD (that is allowed if per-case agreed with customer) which means we could get paid before an installation is complete - so we can again make it so not actually giving credit. We could even as for a fast payment bank transfer before shipping goods. We are not doing credit cards these days.
Indeed, it seems to me that we could make it that everything we do with consumers is not on credit at all, surely?
Though there are phone calls on VoIP and extra usage on broadband. That is tricky as it is not due until we invoice, as far as we are concerned, but we are allowing calls on credit I suppose. Maybe we should do a pre-pay for that? Would be possible to change to that. We are talking consumers not business here.
Even so, the Act mentions ongoing accounts, so what we do may simply not count anyway!
Or I could just pay up every few years. I suspect any professional advice would say "pay up" as that is the safe answer for any solicitor to say.
What worries me slightly is that this now has a surcharge towards the financial ombudsman or some such. I have dealt with an ombudsman before, and I am now concerned in case we are inadvertently liable to some other crowd of muppets. I am not in the business of lending money, and the last thing we need is someone referring us to a financial ombudsman. I would rather change the way we work than have that!
Obviously no changes proposed at the moment (we have renewed our licence) , but if we do find we are able to avoid the licence, and especially if we are tied in to some new ombudsman madness now, we may make changes. The good news is most consumers stay the same with a fixed bill and DD on 1st of each month so only a minor change for a few consumers, and no change for businesses.
Lets see what I find.
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