The papers and minutes have been published on the and the outcomes of the discussions are summarised in this document. Making DAS work for advisers The group were asked to consider what could be done to encourage a higher DAS take up, particularly in the private sector. Members of the group reviewed statistics produced in respect of the provision of DAS. Feedback received from the group included reports that obtaining FCA authorisation can be overly burdensome and costly and some IPs feel that they are being doubly regulated, given that they administer insolvency products. There is also the issue that many private organisations do not feel that DAS is commercially viable. Discussions focussed on the following points and the outcomes are summarised below: How can we improve the take up of DAS from the advice sector? Change the payments distribution function There were no objections from the group in terms of AiB taking on a PD role, either as last resort, or nominated to do so by the money adviser on behalf of the debtor. No objections from the group for any firm with the relevant FCA permissions being able to do their own DAS payments distribution. CMA firms who want to do PD work should be able to do so. If a CMA wants to act as PD, they should do so in ALL cases, not just those paying a lot of money (the argument was that it may not be viable for a company to do PD work where there are small amounts of a contribution being made). The holistic approach of the debtor having the same person/organisation dealing with their DAS does not lend itself to the CMA being able to opt out of acting as PD just because the contributions are low. The group agreed. However, Private arrangements should also be permissible in the event of smaller IP firms not wanting to invest in the time, infrastructure or IT to deliver payments distribution. These organisations would do NO PD work, but would/could still act as CMA. They should be able to default the PD function to another organisation under a private agreement (as long as they have relevant permissions) or the case could default to AiB as PD of last resort. Unanimous agreement that all case management be done via the eDEN case management system. All parties should not be required to engage directly with eDEN but, as a minimum requirement, they must demonstrate their system has functionality to interface with eDEN. By having all actors interact with eDEN, the DAS Administrator will be able to ensure transparency and visibility for all in the DAS process for case. For
The papers and minutes have been published on the and the outcomes of the discussions are summarised in this document. Making DAS work for advisers The group were asked to consider what could be done to encourage a higher DAS take up, particularly in the private sector. Members of the group reviewed statistics produced in respect of the provision of DAS. Feedback received from the group included reports that obtaining FCA authorisation can be overly burdensome and costly and some IPs feel that they are being doubly regulated, given that they administer insolvency products. There is also the issue that many private organisations do not feel that DAS is commercially viable. Discussions focussed on the following points and the outcomes are summarised below: How can we improve the take up of DAS from the advice sector? Change the payments distribution function There were no objections from the group in terms of AiB taking on a PD role, either as last resort, or nominated to do so by the money adviser on behalf of the debtor. No objections from the group for any firm with the relevant FCA permissions being able to do their own DAS payments distribution. CMA firms who want to do PD work should be able to do so. If a CMA wants to act as PD, they should do so in ALL cases, not just those paying a lot of money (the argument was that it may not be viable for a company to do PD work where there are small amounts of a contribution being made). The holistic approach of the debtor having the same person/organisation dealing with their DAS does not lend itself to the CMA being able to opt out of acting as PD just because the contributions are low. The group agreed. However, Private arrangements should also be permissible in the event of smaller IP firms not wanting to invest in the time, infrastructure or IT to deliver payments distribution. These organisations would do NO PD work, but would/could still act as CMA. They should be able to default the PD function to another organisation under a private agreement (as long as they have relevant permissions) or the case could default to AiB as PD of last resort. Unanimous agreement that all case management be done via the eDEN case management system. All parties should not be required to engage directly with eDEN but, as a minimum requirement, they must demonstrate their system has functionality to interface with eDEN. By having all actors interact with eDEN, the DAS Administrator will be able to ensure transparency and visibility for all in the DAS process for case. For