Recommendations & Conclusions
22 items
1
Conclusion
Eighth Report - SME Finance
Accepted
Small and medium-sized enterprises make a large contribution to the UK economy, accounting for over half of total business employment and turnover. SMEs are struggling with narrow access to finance in the face of rising cost pressures and higher interest rates and are generally pessimistic about their ability to raise …
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Small and medium-sized enterprises make a large contribution to the UK economy, accounting for over half of total business employment and turnover. SMEs are struggling with narrow access to finance in the face of rising cost pressures and higher interest rates and are generally pessimistic about their ability to raise funds. Furthermore, apathy about seeking finance is a concerning trend amongst SMEs, and this further reduces access to and awareness of potential sources of business investment. All these pressures will be felt most acutely by the smallest businesses in the SME population, who may have the least resources to withstand difficult economic conditions. (Paragraph 13) Basel 3.1 and the SME supporting factor
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Government response AI summary
The government welcomes the report on SME finance, recognising their significant contribution and challenges, and commits to a range of actions including launching consultations by Spring 2025, extending the SME Digital Adoption Taskforce, announcing a £4m pilot package for tech adoption, and bringing forward a …
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HM Treasury
2
Conclusion
Eighth Report - SME Finance
Acknowledged
The removal of the SME supporting factor under Basel 3.1 threatens to undermine the UK’s SME finance market by increasing capital requirements on lenders to SMEs. This will drive up the cost of finance for SMEs and may restrict the supply of lending as banks shift their loans away from …
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The removal of the SME supporting factor under Basel 3.1 threatens to undermine the UK’s SME finance market by increasing capital requirements on lenders to SMEs. This will drive up the cost of finance for SMEs and may restrict the supply of lending as banks shift their loans away from the market. At a time when costs are tight and acceptance rates for finance low, anything that unnecessarily damages the availability of finance to SMEs is unacceptable. Other jurisdictions like the United States and European Union are also not pursuing as strict an interpretation of Basel with regards to SME lending so removal of the SME support factor risks putting the UK out of step with international peers and competitors, with negative consequences for the competitiveness of the UK market.
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Government response AI summary
The government acknowledged the Committee’s concerns regarding the removal of the SME supporting factor under Basel 3.1 but made no specific commitments to action.
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HM Treasury
3
Conclusion
Eighth Report - SME Finance
Acknowledged
The PRA must ensure that the final implementation of the Basel 3.1 standards leaves capital requirements on SME lending no more stringent than they are under the current system and that international competitiveness with the EU and the US is not harmed. (Paragraph 26) Dispute resolution
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The PRA must ensure that the final implementation of the Basel 3.1 standards leaves capital requirements on SME lending no more stringent than they are under the current system and that international competitiveness with the EU and the US is not harmed. (Paragraph 26) Dispute resolution
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Government response AI summary
The government acknowledges the Committee’s concerns regarding the removal of the SME supporting factor under Basel 3.1 but provides no commitment to action.
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HM Treasury
4
Conclusion
Eighth Report - SME Finance
Acknowledged
We support the Financial Ombudsman Service in its role as the primary mechanism for SME banking disputes. We note concerns that the FOS is primarily equipped to deal with less complex cases but note the efforts undertaken by the organisation to improve specialist resource.
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We support the Financial Ombudsman Service in its role as the primary mechanism for SME banking disputes. We note concerns that the FOS is primarily equipped to deal with less complex cases but note the efforts undertaken by the organisation to improve specialist resource.
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Government response AI summary
The government supports the FOS's role, noting its ongoing programme to improve service following a 2021 review, and commits to continuing regular engagement with the FOS to address operational issues and ensure aligned rules.
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HM Treasury
5
Recommendation
Eighth Report - SME Finance
Accepted
HM Treasury and the FCA should continue their dialogue with the FOS and keep resourcing under active review, to ensure that it has the prerequisite capacity and capability to serve the majority of the SME community.
Government response AI summary
The government accepts the recommendation, stating it will continue engagement with the FCA and FOS, addressing relevant resourcing issues, and aligning FOS rules. It also outlines broader measures announced by the Chancellor to modernise the FOS framework and improve its operational effectiveness.
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HM Treasury
6
Conclusion
Eighth Report - SME Finance
Deferred
The BBRS has seen a far smaller number of cases than some expected. This could be due to low demand, but is also likely to be due to the nature of the eligibility criteria attached to it, as shown by the rejection rate of cases. In the best-case scenario, the …
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The BBRS has seen a far smaller number of cases than some expected. This could be due to low demand, but is also likely to be due to the nature of the eligibility criteria attached to it, as shown by the rejection rate of cases. In the best-case scenario, the 55,000 businesses outside of the FOS’ remit would never have been fully served by the scheme, because only the seven participating banks were in scope. (Paragraph 58) 36 SME Finance
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Government response AI summary
The government notes the committee's conclusions and the BBRS's decision to close, stating that further decisions about the service are a matter for the independent BBRS in discussion with relevant parties.
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HM Treasury
7
Conclusion
Eighth Report - SME Finance
Not Addressed
There is no clear evidence that the seven participating banks control the BBRS on an operational level. However, the structure and remit of the BBRS were determined with their consent. Dispute resolution must be independent, and perhaps as importantly, be seen to be independent of the financial services industry. Despite …
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There is no clear evidence that the seven participating banks control the BBRS on an operational level. However, the structure and remit of the BBRS were determined with their consent. Dispute resolution must be independent, and perhaps as importantly, be seen to be independent of the financial services industry. Despite the assurances we have been given to the contrary, this does not appear to have been the case with the BBRS.
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Government response AI summary
The government notes the committee's conclusion regarding the Business Banking Resolution Service's (BBRS) perceived lack of independence, and states that the BBRS will close to new registrations on 13 December 2024, with its future being a matter for the BBRS itself.
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HM Treasury
8
Conclusion
Eighth Report - SME Finance
Deferred
The BBRS is not fit for purpose in providing alternative dispute resolution to the 55,000 SMEs who fall outside of the FOS’ thresholds and this service should close as originally planned.
Government response AI summary
The government did not address the recommendation to close the BBRS, instead highlighting the role and importance of the Financial Ombudsman Service (FOS) for dispute resolution.
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HM Treasury
9
Conclusion
Eighth Report - SME Finance
Acknowledged
HM Treasury must find a way to continue to meet the dispute resolution needs of those SMEs ineligible for FOS access (including considering whether the FCA was correct in assuming that expanding the FOS’ thresholds would be a disproportionate cost). A consultation on a replacement mechanism must take place by …
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HM Treasury must find a way to continue to meet the dispute resolution needs of those SMEs ineligible for FOS access (including considering whether the FCA was correct in assuming that expanding the FOS’ thresholds would be a disproportionate cost). A consultation on a replacement mechanism must take place by year end 2024.
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Government response AI summary
The government generally supports the Financial Ombudsman Service (FOS) and describes its important role in resolving disputes, but does not commit to finding a new mechanism for ineligible SMEs or consulting on a replacement.
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HM Treasury
10
Recommendation
Eighth Report - SME Finance
Accepted
HM Treasury and the FCA should also continue to the keep resourcing of the FOS under active review to ensure that it has the prerequisite capacity and capability to serve the majority of the SME community. (Paragraph 62) Business debanking
Government response AI summary
The government commits to continuing engagement with the FCA and FOS to address resourcing issues, referencing a package of measures announced at Mansion House, including a Call for Input, an updated Memorandum of Understanding, and a strengthened Wider Implication Framework to modernise the FOS and …
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HM Treasury
11
Conclusion
Eighth Report - SME Finance
Accepted
Any SME with a legal business should be able to access a bank account. Banks may need to close business accounts because of regulatory requirements and concerns around financial crime, but thousands of accounts are being closed for vaguely defined reasons relating to “risk appetite” or “reputational risk”. What qualifies …
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Any SME with a legal business should be able to access a bank account. Banks may need to close business accounts because of regulatory requirements and concerns around financial crime, but thousands of accounts are being closed for vaguely defined reasons relating to “risk appetite” or “reputational risk”. What qualifies for this type of account closure varies from bank to bank with little regulatory guidance. SMEs deserve to know why their account has been closed, and the lack of transparency, alongside inconsistency in how criteria are being applied, is unacceptable.
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Government response AI summary
The government agrees that account closure requirements need improving and intends to bring forward legislation to ensure customers receive detailed explanations and longer notice periods when accounts are closed, except in financial crime situations.
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HM Treasury
12
Conclusion
Eighth Report - SME Finance
Acknowledged
The FCA should continue their work into better understanding how financial institutions are using criteria like “reputational risk” or “risk appetite” and report their findings by the end of Q2 2024. It is essential that the FCA publish clear instructions by Q3 2024 to the market about how such criteria …
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The FCA should continue their work into better understanding how financial institutions are using criteria like “reputational risk” or “risk appetite” and report their findings by the end of Q2 2024. It is essential that the FCA publish clear instructions by Q3 2024 to the market about how such criteria can and cannot be used within the existing regulations. These instructions should be designed to ensure consistency between institutions and prevent the above criteria from being applied more broadly than the law permits. HM Treasury should keep the findings and subsequent action taken by the FCA under review, and it should be prepared to widen the FCA’s remit as needed should the action taken not be robust enough under the current regulations.
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Government response AI summary
The government stated its commitment to ensuring SMEs have appropriate access to redress and proportionate regulation but did not commit to the specific actions or timelines recommended for the FCA or HM Treasury.
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HM Treasury
13
Recommendation
Eighth Report - SME Finance
Acknowledged
The FCA should also require banks to submit quarterly data on business account closures to assist their wider review. The FCA should publish an aggregated form of this data on a periodic basis to improve transparency over business debanking and allow SMEs to make informed decisions on their choice of …
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The FCA should also require banks to submit quarterly data on business account closures to assist their wider review. The FCA should publish an aggregated form of this data on a periodic basis to improve transparency over business debanking and allow SMEs to make informed decisions on their choice of finance provider. The FOS should also continue to publish statistics on complaints from businesses around account closures. We would not want Environmental, Social and Governance SME Finance 37 measures requested by investors to be interpreted as meaning that businesses engaged in perfectly legal defence or energy activities were unable to open a bank account.
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Government response AI summary
The government states a general commitment to ensuring SMEs have appropriate access to redress and proportionate regulation, but provides no specific actions regarding data collection or publication as recommended.
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HM Treasury
14
Conclusion
Eighth Report - SME Finance
Acknowledged
We welcome the Treasury’s proposed rules changes on debanking, which will provide a greater deal of transparency to customers who suffer from an account closure. HM Treasury should introduce these regulations before the parliamentary summer recess,
Government response AI summary
The government expresses a general commitment to ensuring SMEs have appropriate access to redress and proportionate regulation, but does not specify action to introduce the proposed debanking regulations before the parliamentary summer recess.
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HM Treasury
15
Conclusion
Eighth Report - SME Finance
Acknowledged
We commend the British Business Bank for its role in providing support to SMEs. We would like to see more smaller businesses visiting the Finance Hub and making use of its resources, as well as wider BBB programmes.
Government response AI summary
The government agrees on the British Business Bank's important role in supporting SMEs and expresses a shared desire for more SMEs to utilise its Finance Hub, committing to work with the BBB to improve access to finance through targeted interventions.
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HM Treasury
16
Recommendation
Eighth Report - SME Finance
Accepted
Government, including HM Treasury and the Department for Business and Trade, should consult with the BBB on an ongoing basis to ensure that everything possible is being done to raise awareness and increase engagement from the SME community. This should include assessing whether the BBB has sufficient resources to publicise …
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Government, including HM Treasury and the Department for Business and Trade, should consult with the BBB on an ongoing basis to ensure that everything possible is being done to raise awareness and increase engagement from the SME community. This should include assessing whether the BBB has sufficient resources to publicise its services effectively. Government should subsequently implement criteria by which they can assess the effectiveness of the BBB in reaching SMEs, which they should publish annually.
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Government response AI summary
The government agrees with the recommendation and commits to working with the British Business Bank (BBB) to improve SME access to finance, providing over £1 billion in funding for the BBB. It notes that the BBB has already published an SME Impact Report addressing the …
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HM Treasury
17
Conclusion
Eighth Report - SME Finance
Deferred
The Recovery Loan Scheme appears to have been successful in supporting SMEs with access to finance throughout the pandemic and beyond. We welcome HM Treasury’s decision to extend and rebrand it into a “Growth Guarantee Scheme”, which can provide support to many more businesses seeking to access finance in the …
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The Recovery Loan Scheme appears to have been successful in supporting SMEs with access to finance throughout the pandemic and beyond. We welcome HM Treasury’s decision to extend and rebrand it into a “Growth Guarantee Scheme”, which can provide support to many more businesses seeking to access finance in the coming years.
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Government response AI summary
The government responded with a general statement about the importance of banking services and financial inclusion, rather than directly acknowledging the Committee's welcome for the new Growth Guarantee Scheme.
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HM Treasury
18
Conclusion
Eighth Report - SME Finance
Acknowledged
HM Treasury and the BBB should consult on the merits of making the Growth Guarantee Scheme permanent, in order to provide a foundational support programme, which can be scaled up appropriately in a crisis. This would build long term security in the accessibility of finance for the SME population and …
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HM Treasury and the BBB should consult on the merits of making the Growth Guarantee Scheme permanent, in order to provide a foundational support programme, which can be scaled up appropriately in a crisis. This would build long term security in the accessibility of finance for the SME population and provide a greater level of certainty. (Paragraph 96) Personal guarantees
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Government response AI summary
The government states a general commitment to high standards of protection and financial inclusion in the banking sector, but does not address consulting on making the Growth Guarantee Scheme permanent.
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HM Treasury
19
Conclusion
Eighth Report - SME Finance
Acknowledged
Disproportionate use of personal guarantees may be a factor in driving down access to finance, either owing to lack of collateral or simple risk aversion from businesses who do not wish to take them out. We support the FCA’s investigation into the fair and proportionate use of personal guarantees that …
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Disproportionate use of personal guarantees may be a factor in driving down access to finance, either owing to lack of collateral or simple risk aversion from businesses who do not wish to take them out. We support the FCA’s investigation into the fair and proportionate use of personal guarantees that fall within its existing remit. The FCA’s remit is set by Parliament, and we do not feel that widening it would be appropriate at this time. This is because the unintended consequences of introducing new regulatory frameworks to deal with specific issues in SME lending market could actually result in a reduction in the accessibility of finance for SMEs. We may revisit this in the future and will monitor the FCA’s progress on the matter of personal guarantees.
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Government response AI summary
The government provides a general statement of commitment to high standards of protection and financial inclusion, without specifically addressing the FCA's investigation into personal guarantees or its remit.
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HM Treasury
20
Conclusion
Eighth Report - SME Finance
Deferred
We agree with the FOS that the current approach to personal guarantees on business lending represents a gap in its remit that fails to provide the kind of support to 38 SME Finance SMEs that the service exists for. The fact that the FOS cannot assist business owners or directors …
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We agree with the FOS that the current approach to personal guarantees on business lending represents a gap in its remit that fails to provide the kind of support to 38 SME Finance SMEs that the service exists for. The fact that the FOS cannot assist business owners or directors over misapplied guarantees, but can do so for consumers, represents an unfair inconsistency in how the FOS supports consumer versus business cases.
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Government response AI summary
The government notes that the committee's conclusion regarding the FOS's inconsistent support for SMEs on personal guarantees is primarily for the independent Financial Conduct Authority (FCA) to consider.
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HM Treasury
21
Recommendation
Eighth Report - SME Finance
Deferred
The FCA should provide the FOS with the necessary powers to address personal guarantees for SMEs, so that their service is consistent with consumers. The FCA should also investigate widening the FOS’s remit to cover the other gaps they identified and keep the Committee informed of their conclusions.
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The FCA should provide the FOS with the necessary powers to address personal guarantees for SMEs, so that their service is consistent with consumers. The FCA should also investigate widening the FOS’s remit to cover the other gaps they identified and keep the Committee informed of their conclusions.
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Government response AI summary
The government notes these recommendations for widening FOS powers regarding personal guarantees for SMEs and investigating other gaps are primarily intended for the independent Financial Conduct Authority (FCA) to consider.
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HM Treasury
22
Conclusion
Eighth Report - SME Finance
Deferred
Unfair use of personal guarantees has the potential to constrain growth and investment for SMEs, particularly the smallest businesses. We welcome HM Treasury’s review on this matter, and look forward to seeing what it will do to ease the burden on the smallest businesses. (Paragraph 113) SME Finance 39
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Unfair use of personal guarantees has the potential to constrain growth and investment for SMEs, particularly the smallest businesses. We welcome HM Treasury’s review on this matter, and look forward to seeing what it will do to ease the burden on the smallest businesses. (Paragraph 113) SME Finance 39
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Government response AI summary
The government completely changed the subject, welcoming the FCA's work on bank account rejections and closures and generally discussing access to banking services, instead of addressing the recommendation about personal guarantees for SMEs.
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HM Treasury