Credit reporting: Interim Working Group (IWG)

IWG Report One

You can find the IWG’s first report (PDF) here.[6]

Report One – the FCA’s interim response  

The FCA welcomes the IWG’s first report (PDF)[6], which sets out its recommendations on what the CRGB should do. We thank the Chair and secretariat and IWG members for the report and for engaging with us collaboratively. 

We will provide detailed feedback to the IWG upon publication of their final report later this year. In the interim, we will provide feedback on key issues or concerns, so that they can be considered by the IWG.  

We particularly welcome the proposed purpose and scope of the three proposed objectives and the focus on outcomes. We look forward to the IWG’s subsequent reports expanding on these areas and others still subject to discussion and consultation, in particular the legal framework in which CRGB should operate.

We would like the IWG to note the following considerations as they continue their work: 

• We expect that the Consumer and Future-Looking Objectives are given equal priority and weight as the Operational Objective. This will enable the CRGB to achieve the outcomes proposed in the CIMS reports.
• We expect that a later IWG report will cover CRGB’s relationships with other relevant regulators in addition to the FCA.

IWG Report Two 

You can find the IWG’s second report here (PDF)[7].

Report Two – the FCA’s response

The FCA welcomes the IWG’s second report (PDF)[8], which sets out its recommendations on how the CRGB should be constituted. We thank the Chair, secretariat and IWG members for collaborating and compromising to produce recommendations, particularly given the complex issues involved.

Our feedback on key issues in the IWG’s second report

We would like the IWG to note the following considerations as they continue their work.

Fair representation

We welcome the safeguards proposed in this report to ensure that all stakeholders are represented equitably in CRGB’s decision-making. In future reports, we expect that the IWG will carefully consider the need for strong representation from consumers and challenger market participants on an ongoing basis. This will include considering how safeguards apply to the Board’s decision-making. We expect safeguards to ensure Board members are not unfairly sidelined. We would also strongly suggest a permanent consumer council, given the importance of ensuring ongoing consumer representation in the CRGB. It is also important that the CRGB can make decisions in an agile manner. As stated in our final market study report, we believe that this could be achieved through a decision-making process that doesn’t require all members to agree and is more transparent, fair and representative. 

Accountability

We expect that a later IWG report will further explain how CRGB will be held accountable and how it will engage with regulators. We expect this to include a mechanism for consultation with the FCA on very significant constitutional or policy decisions. It is important that industry participants, consumers, and regulators can hold the CRGB to account for its actions. This will be particularly important given the proposal that the directors will also be the CRGB’s only members, risking a lack of accountability. IWG should look at the adequacy of the proposed process for appealing Board decisions and the appropriateness of the Board reviewing its own decisions.   

Funding

We welcome the significant progress on the CRGB funding model and look forward to seeing the approach to annual subscription fees. We welcome that the IWG is considering competition issues in relation to the CRGB funding model, and encourage it to continue to do so in future reports. 

Regulatory ‘endorsement’

We understand the need for CRGB to have powers to enforce industry rules. We note the report comments about strengthening credibility of the rules through some form of regulatory endorsement. While we recognise certain industry codes[8] (which cover unregulated activities) and industry guidance on FCA requirements, it is not immediately clear that CRGB’s data sharing rules would fall into either of these categories. We are open to further discussion on this point. We would not consider an MoU with the CRGB (a document setting out mutually agreed arrangements for cooperation and coordination) to be an ‘endorsement’ as is proposed.  

Responses to specific questions the IWG has asked us  

Nominations to the CRGB Board

The IWG proposes that an FCA representative sits on an initial nominations committee for the CRGB’s independent chairs and directors. We would be content to be involved in this process to help establish the CRGB Board, should the IWG maintain this proposal in their final report. 

Proposed FCA levy

The IWG also requests that we consider supporting an FCA levy fees model, alongside its primary funding proposal, aiming to minimise the complexity of collecting funding. Given the CRGB will be an independent industry body, we do not think it would be appropriate for the FCA to be responsible for collecting the CRGB’s fees. We currently only do this for other regulatory bodies (eg the Financial Ombudsman Service[9] and the Financial Services Compensation Scheme[10]). As such, we would strongly encourage the IWG to look at other collection models.

IWG Report Three

Given the complexity of operationalising the recommendations in the first two IWG reports, the IWG chose to issue a set of consultation papers[11] in lieu of a third report. Industry consultation took place in November 2024 and February 2025. These published papers reflect what was shared with industry and accounts for industry and FCA feedback.

Report three papers – the FCA’s feedback

The FCA provided feedback[12] to the IWG on their report 3 papers, for the IWG’s consideration prior to publication.

IWG Final Report 

See the IWG’s Final Report[13].

IWG Final Report – the FCA’s feedback

In July 2025, the FCA published feedback[2] to the IWG’s Final Report, and provided an accompanying update[14].

IWG response to FCA Final Report feedback 

The IWG thank the FCA for their consideration of the Final Report and have published the following response[15]. 

The IWG and FCA held a joint event on 5 September 2025 at the FCA’s London office to provide an update to industry on the progress being made towards the set up of the Credit Information Governance Body (CIGB). The event also marked the official handover from the IWG secretariat team to the newly hired CIGB staff in taking forward the IWG’s final report recommendations.

Graeme Reynolds, FCA Director of Competition, opened the event by reflecting on the IWG’s progress to date. Graeme expressed the FCA’s support for the IWG’s recommendations and thanked the industry for their effective collaboration. Alison Walters, FCA Director of Consumer Finance, emphasised the FCA’s commitment to both the CIMS FCA and industry-led remedies and made clear that the FCA would continue to have a relationship with and support the CIGB going forward.

Jackie Keogh, IWG independent chair, provided an overview of the IWG’s recommendations. Jackie particularly focused on explaining how stakeholders will be able to engage with the CIGB, through Advisory Councils, the Board and via open consultations.

Next, Peter Tutton (StepChange) set out how CIGB will aim to achieve good consumer outcomes and how the infrastructure of the organisation is designed to support this. Peter expressed his satisfaction with the IWG process and how consumer views were effectively accounted for throughout.

Jane Keywood, Equifax, then gave an update on the ongoing CIMS industry-led remedies work. Jane explained that three working groups have been established to identify quick wins and improvements for consumers while the CIGB is being established. Jane welcomed further involvement from industry and consumer groups in this work and asked that interested stakeholders get in touch.

Kevin Ludwick, the CIGB independent chair, was introduced to attendees and emphasised the importance of industry supporting the new CIGB staff as they take forward the transition from SCOR to the new governance entity.

The audience then asked questions of all the speakers, predominately around the CIMS FCA-led remedies and expected timelines for the operationalisation of the CIGB. The debate was open and far-reaching, with attendees also wanting to better understand how CIGB will approach transparency and accountability as well as the implications for firms of the CIGB’s subscription model.

The CIGB team are working to set up the CIGB website, where further information and frequent updates on their workplan and progress will be published. In the meantime, any queries can be directed to [email protected].

Thank you to the FCA for use of their facilities and to the attendees for their openness and contributions.

Following the FCA's Credit Information Market Study[17] reports, Equifax, Experian and TransUnion have set up working groups on:

• notice of corrections and disputes
• access to statutory credit reporting
• common data format

Before the CRGB is formally set up, these working groups aim to identify non-competitive, quick-win opportunities for the proposed industry-led remedies.

All working groups have kept the FCA updated on their activities and are aligned with the principles for industry remedy development[16].

The groups have published an update on progress below. They plan to reach out to all stakeholders for their views.

Read the report (PDF)[17]

The IWG held an event on 23 September 2024 at the FCA’s London office to update data contributors and users on progress on its work. The event was attended by over 70 parties representing lenders, CISPs, fintechs and regulators.

Jackie Keogh, IWG independent chair, opened the event by providing an overview of the recommendations made by the IWG in report two. She explained that the future credit reporting governance body (CRGB) will be a company limited by guarantee, with a single tier structure, managed by a Board of independent and industry nominated directors. The IWG outlined decision-making processes along with the funding model and the fact that CRGB will gain its powers from contract law. 

The audience asked questions of both the FCA and the IWG chair, predominately on the governance model, which understandably extended into other FCA and industry-led remedies. The debate was open and far-reaching with questions on timelines, remedy prioritisation and the FCA’s future engagement in CRGB.

Breakout sessions followed, focusing on how attendees wish to participate in and be informed of CRGB’s activities. They also provided valuable insight on expectations in terms of accountability and transparency for the new entity. The input from these sessions will contribute to the recommendations to be published in report three.

Thank you to the FCA for use of their facilities, the IWG members for their support in running the event and, most importantly, the participants for their openness and contributions.

The IWG hosted its first large event to engage with data users and contributors at the FCA’s London office on 26 March 2024.

The focus of the event was to share progress to date on the work of the IWG, validate key content in the first report and seek input on central subjects in the second report.

The event was attended by 50 participants representing mainstream and alternative lenders, trade associations, partner regulators, the Treasury and some of the IWG members.

The FCA opened the event by outlining the state of the credit information industry and its expectations as outlined in the Credit Information Market Study (CIMS) final report. The participants provided feedback on the proposed Credit Reporting Governance Body (CRGB) purpose, which showed 89% of the attendees either agreed or strongly agreed with the core purpose. Feedback highlighted the need to clarify the term 'all stakeholders' and make sure consumers were specifically mentioned.

The attendees also considered the 3 proposed CRGB objectives which received strong support. In all, 98% of the voting participants agreed there should be an operational objective, 86% agreed a consumer objective is needed and 81% supported a future-looking objective.

Finally, break-out sessions delivered significant constructive input for the IWG to consider about the principles to be applied to the governance of the CRGB.

Feedback after the event from attendees showed that they valued the opportunity to influence the design of the CRGB.

A further data user and contributor event will be held later in the year. The next major event will be for consumers on 25 June 2024. Further details will be provided in the coming weeks.

Thank you to the FCA for use of their facilities, the IWG members for their support in running the event and, most importantly, the participants for their openness and contributions.

It is with great pleasure that I am writing this first communication to the Credit Information Market participants. I took up my role as Independent Chair of the Interim Working Group (IWG) on 2nd January 2024. The IWG was created to make recommendations to the FCA on the reform of industry governance arrangements. The reform to the governance is seen as a key precursor to many of the other potential remedies that are proposed in the FCA final report[1].

The IWG kick started their year with a meeting on 18th January. The minutes of the meeting can be found at the bottom of this page under ‘Group meetings’, minutes will be published for all future meetings. Being the first meeting, much of the agenda focused on what we need to do and how we plan to do it. The proposed approach has been submitted to the FCA for consideration as part of the sign off of the Terms of Reference. Additional detail on the workplan will be included with the publication of the Terms of Reference in the coming weeks.

The IWG members are keen to ensure the thoughts of as may parties can be captured as part of the governance effort. Feedback can be provided directly to IWG members, via [email protected] or during the industry events that will be held and published here in the coming months.

This meeting finalised the IWG's recommendations to the FCA before publication of its final report.

The IWG began by discussing the industry feedback received following consultation on the draft final report, including:

• The need to better define CRGB's role in relation to commercial data.
• CISPs positioning as CRGB subscribers.
• The proportionality of the proposed decision-making safeguards.
• Voting and nominations at CRGB's Advisory Councils.
• Further clarification on the transition from SCOR to CRGB.

The IWG agreed to adapt the final report to address this feedback, including: 

• Adding a new chapter on CRGB's recommended approach to adopting SCOR’s rules relating to commercial data.
• Clarifying that CISPs are expected to subscribe to the CRGB and will be subject to the recommended governance and funding models.
• Adapting the minority safety net safeguard to account for smaller firms.
• Increasing the number of votes at the CRGB's Advisory Councils to reflect the diversity of its cohorts and ensure the Board is made aware of differences in voting.
• Adding further detail to the proposed transition plan, including expected timings and the source of funding for these transition activities.

Following these changes, the IWG agreed to submit its final recommendations to the FCA and publish its report on 23 May 2025.

The IWG will continue to provide support to the IWG's independent chair and secretariat in the short-term as they undertake initial transition activities, including the hiring of the CRGB's chair.

13 March 2025

This meeting progressed the Interim Working Group’s (IWG) fourth stage topics, as set out in the revised Terms of Reference[5] on page 13.

The IWG began by discussing industry feedback on topics circulated for consultation in February, including:

• The proposed CRGB funding model.
• How the advisory council and Board processes will work.

The IWG agreed to clarify aspects of the proposals, including the membership of advisory councils and the flow of information between the councils and the Board. 

The proposed funding model was discussed in detail, particularly around perceptions of proportionality and fairness in terms of subscription fees.

The IWG agreed to provide more transparency as to the split of funding by cohort size and fees paid, by explaining in more detail how the proposed funding model is considered both fair and reasonable.

The proposed thresholds for special procedure board decisions were also discussed, with much industry feedback suggesting a higher threshold of 75% was appropriate. The IWG agreed to this, noting concerns from some members about the efficiency of CRGB’s decision-making.

Decision-making safeguards were also debated, particularly the proposal for Board cohorts to use a safety net to delay decisions likely to have a significant financial impact on firms. Some concern was raised around smaller firms’ ability to use this safety net, however the IWG felt the proposal was proportionate and the safety net should only be used in exceptional circumstances. 

The IWG also reviewed the first draft of the final report circulated by the IWG secretariat, with points of clarification raised and agreed. 

Questions were discussed again about how the CRGB model should be applied to some industry players, particularly those with a unique business model not currently accounted for within the industry data sharing rules. The IWG Chair and secretariat will seek more clarity on this topic, but it was ultimately agreed that the recommendation on some subscribers could be positioned as a Chair recommendation if compromise cannot be found in the short term.

The IWG agreed to issue the draft final report for industry consultation on 17 March 2025, sharing feedback with the secretariat by 4 April. 

The next IWG meeting will be on 11 April 2025. 

16 January 2025

This meeting furthered progress on the third stage topics, set out in the revised Terms of Reference (PDF)[23] on page 12.

The IWG began by discussing the principle of a minority safety net, to be utilised before Board decisions are finalised, which will ensure decisions which have a material adverse financial impact or result in materially disproportionate impacts are given due consideration by the Board and alternatives are thoroughly considered. The safety net would be available to all Board cohorts and the IWG welcomed this further safeguard to ensure they retain appropriate control over their businesses’ own cost base and models. The IWG were clear about the need to ensure the safety net is only utilised in exceptional circumstances and is not abused by firms resisting industry change, as such significant debate was had around the criteria to trigger the ability to utilise the safety net. It was agreed the IWG secretariat will give further consideration to these criteria and any caveats needing to be put in place to allow smaller firms to voice their discontent with Board decisions.

The IWG then moved on to finalise the recommended roles, constitution, and operationalisation of the 3 advisory councils currently proposed for the CRGB. IWG members were satisfied that their previous feedback had been accounted for and agreed to sign off this paper to be shared more widely with industry for consultation before the IWG’s final report is issued.

The IWG then continued previous discussions on the proposed CRGB fee structure model. The IWG secretariat explained that further data had been obtained on the lender cohort and as such more work had been undertaken to ensure the lender tiers and corresponding fees were proportionate to those of other cohorts. There was general acceptance from the IWG that the accuracy of the data model has reached its limit, particularly given difficulties faced in determining exactly how many firms are likely to subscribe to CRGB. The IWG also accepted that the fee model only aims to set out the structure for year one and would need to evolve over time, this responsibility would fall to CRGB’s Board. As such, a paper will be produced outlining the fee model which will be issued to industry in the coming weeks to support IWG discussions with firms likely to be asked to provide prepayment to fund the set-up of the CRGB.

Lastly, the IWG secretariat provided an update to the members on transition planning and secured IWG’s support in setting up CRGB as a legal entity imminently.

The next IWG meeting will be held on 13 February 2025.

12 December 2024

This meeting furthered progress on the third stage topics, set out in the revised Terms of Reference (PDF)[24] on page 12.

The IWG continued their discussion on which firms within the credit information industry will be expected to subscribe to CRGB and the ways in which CRGB’s policing and oversight models will apply to those subscribers. Likewise, the IWG discussed the need for CRGB to be inclusive of firms with different business models and how the PoR will need to evolve once adopted by the CRGB to allow for the involvement of CISPs and a wider variety of CRAs. It was agreed the IWG secretariat will produce an updated proposal for members to consider at the next monthly meeting.

Continuing from the IWG’s last meeting in November, the IWG secretariat provided the members with further funding scenarios to highlight different options and the implications for various cohorts and tiers. There is a desire to have more tiers for cohorts with a large number of firms and for the model to ensure the fee distribution between cohorts is proportional. The approach IWG should take to prefunding the set-up of the entity during the transition from SCOR to CRGB was also discussed and agreed with members. 

The IWG agreed to recommend a proposal for a Board appeals process open to any CRGB subscriber and consumer group. The importance of CRGB establishing appropriate grounds for appeal was discussed to prevent over-use of this appeals process, members recognised the importance of CRGB being able to work at pace, particularly in relation to implementing the CIMS industry-led remedies.

Lastly, the IWG revisited the topic of financial inclusion and how CRGB can account for this within its decision-making. Members recognised the important impact CRGB could have on financial inclusion but were clear that CRGB could only take appropriate action within its remit. Further discussions will be held on this topic in the new year.

The next IWG meeting will be held on 16 January 2025. 

21 November 2024

This meeting continued progress on the third stage topics, set out in the revised Terms of Reference (PDF)[25] on page 12.

The IWG secretariat shared four papers with the IWG members for approval before these papers are made available for the IWG to socialise them with their cohorts. These included: 
• CRGB’s proposed approach to accountability and transparency.
• CRGB’s relationship with government and regulators.
• The proposed industry contracting arrangements once CRGB comes into existence.
• CRGB’s proposed non-compliance and complaints processes.

Following some minor comments, which will be addressed by the IWG secretariat, the papers were approved by the IWG members.

The IWG then revisited the definition of a CRGB subscriber and agreed in principle that those firms that only contribute data but do not utilise it should not be expected to fund CRGB (but will still be expected to subscribe to CRGB). This is because their contribution of data enhances the value of the credit information system, IWG does not want to discourage this contribution by requiring firms to fund. 

The secretariat also presented the updated funding model to the IWG, outlining the recommended annual fees for each cohort and tier of subscriber. An in-depth conversation was had around the importance of proportionality and ensuring the funding model accounts for those firms who will benefit most from CRGB’s governance, including its scheme rules. It was agreed that the secretariat would work to provide the IWG with a few other scenarios to highlight different options and the implications for various cohorts and tiers. 

Lastly the IWG’s external legal advisors presented their view on CRGB’s potential position as a joint controller of the shared data it will govern. The advisors highlighted that the likelihood of a legal challenge, alleging that the CRGB is a joint controller of the shared data is low, as well as the likelihood of the legal challenge succeeding. However, the IWG agreed that the CRGB will need to keep this under review over time, particularly in relation to CRGB’s role in setting contract terms. 

The next IWG meeting will be held on 12 December at the FCA’s offices in London. 

10 October 2024

This meeting continued progress on the third stage report topics, set out in the revised Terms of Reference (PDF)[26] on page 12.

The IWG secretariat team presented the results of the cost model it has built for the credit reporting governance body (CRGB), including assumptions around:

• staff requirements
• outsourcing needs
• set-up costs

These assumptions were acceptable to the IWG members who will recommend a high-level version of the model featuring in the IWG’s third report. Further work will be undertaken over the coming weeks to decide how this cost model applies in terms of the funding requirements of CRGB’s subscribers. 

Report three will be delayed due to the need to:

• include the allocation of costs to subscribers
• decide the composition of the CRGB’s board

Relatedly, the IWG considered in more detail how CRGB’s subscribers are defined and categorised. This involved a debate on the meaning of ‘access’ to the shared data governed by CRGB, given the IWG’s second report set out that any entity that accesses the shared data would be subject to the CRGB funding and policing models. 

The IWG needs to further consider the CRGB’s relationship with entities that have limited access to and/or use of the shared data, particularly in terms of how the CRGB oversees these firms.

The IWG also discussed how the CRGB’s advisory councils will operate, particularly:

• the roles of each council
• how councils will interact with each other on key issues

The IWG secretariat will produce process charts to more clearly show the decision-making flow at CRGB, from tabling of issues up to consideration by the Board.

The next IWG meeting will be held on 21 November 2024.

12 September 2024

This meeting continued the Interim Working Group’s (IWG’s) progression of the third stage report topics, set out in the revised Terms of Reference (PDF)[27] on page 12.

The IWG reflected on stakeholder feedback received in response to its second report and members agreed a way forward in terms of progressing the topics raised in this feedback over the coming weeks.

A detailed discussion was had on the Credit Reporting Governance Body's (CRGB'S) role in terms of policing of its scheme rules and the process that will be followed in the event of non-compliance by CRGB subscribers. The IWG considered different assessment stages which conclude in an independent review. Further evaluation will be needed before the IWG can make a definitive recommendation on this within its third report. However, a standard complaints process was discussed and agreed to by members.

The IWG discussed the CRGB’s approach to its relationship with regulators and Government. A clear framework in terms of proactivity of engagement was agreed to and will form part of the recommendations in the IWG’s third report.

The IWG continued the debate on the role of the CRGB within the design and implementation of the CIMS industry-led remedies and implications for the CRGB’s staffing requirements. IWG members agreed to a split of responsibilities between CRGB staff and industry stakeholders and to input this into the CRGB cost model being built by the IWG secretariat team.

The IWG also discussed the CRGB’s conflict of interest policy and Board protocol. IWG members were comfortable with the processes and safeguards presented and it was agreed to include these as recommendations within the IWG’s third report once the CRGB’s wider Board composition has been given further consideration.

The next IWG monthly meeting will be held on 10 October via Microsoft Teams.

8 August 2024

This meeting of the Interim Working Group (IWG) was the first of several discussions about the third stage report topics, set out in the revised Terms of Reference (PDF)[28] on page 12.

The meeting began with a discussion about  the importance of the Credit Reporting Governance Body (CRGB) being held accountable by its key stakeholders (identified in report one PDF[7]) and acting with transparency. A set of accountability and transparency principles were debated and provisionally agreed by the members covering areas such as CRGB’s publications, engagement with its subscribers and participants, and monitoring compliance and effectiveness both internally and externally.

There were then discussions about the CRGB’s cost model being built by the IWG Secretariat team, the role of the CRGB within the design and implementation of the CIMS industry-led remedies and implications for the CRGB’s staffing requirements. It was agreed that further work will need to be done to better estimate the costs for CRGB of its remedies work as well as its BAU governance activities.

The IWG also discussed the CRGB’s decision-making including its requirements for a quorum, conflicts of interest policy and Board decisions requiring special procedure. Initial discussions were held about the constitution of the CRGB’s advisory councils. These topics will be discussed again with the aim of reaching an agreement on the right approaches.

The next IWG monthly meeting will be held on 12 September at TransUnion’s offices in London.

13 June 2024

This meeting first focussed on the proposed board governance model of the Credit Reporting Governance Body (CRGB). 

The Interim Working Group (IWG) members provisionally agreed to a single tier legal membership model for CRGB, where the Directors on CRGB’s Board will also be the legal members of CRGB. The IWG continue to debate the membership of the board and advisory councils as this underpins many other elements so deserves due consideration. Whilst a mixed board, with an independent chair and an equal split between nominated and independent board members has been agreed in principle, further discussion is still required on the selection process.

Safeguards to make sure consumer groups and smaller businesses operating in the credit information market are sufficiently represented within the CRGB’s governance structure were also debated and provisionally agreed with the IWG members.  But further industry consultation will be needed on this topic.

The IWG also discussed the proposed funding model for the CRGB. The source of CRGB’s funding for its set-up was debated and it was provisionally agreed, subject to internal firm discussions, that a limited number of large firms would pre-pay their annual CRGB subscription fees to cover these costs.

It was also agreed that the IWG secretariat would do further analysis to determine whether a minimum threshold for the annual subscription fee is feasible, whereby firms with turnover below a certain level would not be required to contribute to CRGB’s funding. This will be in addition to further exemptions to payments relating to social good issues.

The next IWG meeting will be on 27 June and will be held online via MS Teams. 

27 June 2024

For the Credit Reporting Governance Body (CRGB) to operate effectively as a governance body, it needs to have the appropriate powers to compel industry to behave according to its pre-agreed rules. In this meeting, the Interim Working Group (IWG) discussed and agreed that contract law was the only viable option for the CRGB, given the current phase of the political cycle. 

The IWG also discussed the liabilities relating to the CRGB as an incorporated entity, namely for its guarantors, directors and senior management. Initial conversations were had around the liabilities for the CRGB in relation to data sharing and contracting, but the IWG will need to continue its work on how the CRGB will operate before any liability implications can be established.

The IWG returned to the issue of the proposed funding model for the CRGB and debated the details of CRGB’s funding exemptions. A social good definition was agreed upon as well as an in-principle turnover exemption, subject to more analysis by the IWG secretariat to establish:

• the exact turnover threshold
• its implications for the entities funding the CRGB

Lastly, the IWG discussed the proposed Board governance model and agreed to recommend a highly debated model within its second report to the FCA. The report will be issued to the FCA on 12 July and published on the IWG landing page on 16 July.

The next IWG meeting will be held on 8 August.

9 May 2024

This meeting continued to work on the second stage report topics, set out in the revised Terms of Reference (PDF)[29] on page 12.
The meeting began with the FCA’s Credit Information Market Study (CIMS) team outlining the FCA’s high-level feedback on report one. The FCA’s feedback[-11] was published on the Interim Working Group’s (IWG) landing page on the 15 May. The initial feedback only addresses issues and concerns to allow for consideration by the IWG in later reports.

The IWG’s external legal advisors, Mills and Reeve, outlined the work they had done on assessing the preferred method of incorporating the Credit Reporting Governance Body (CRGB) as a legal entity. They provided further evaluation on the shortlisted models proposed by the IWG. It was concluded that a company limited by guarantee was the most appropriate incorporation vehicle for the CRGB. The IWG members endorsed the conclusion and the IWG will recommend this method of incorporation to the FCA in its second report. 

Discussions moved onto a more detailed debate on the potential board structure of the CRGB. The main topic of debate focussed on whether an independent or mixed board was most appropriate for the CRGB.

Important points were raised by members about the need to balance the level of subject matter expertise whilst maintaining appropriate independence and keeping costs at a manageable level. It was unanimously agreed that the board should have an independent chair with most, but not all, of the IWG members also deciding that a mixed board would be preferable. There were inconclusive discussions on the split of nominated and independent directors on a mixed board and how this would operate with board committees and/or advisory groups. Further deliberation is needed on governance. 

Funding of the CRGB was briefly discussed, with a focus on the value proposition of the CRGB which will incentivise industry to want to contribute to the CRGB’s funding. An interim IWG meeting has been scheduled on the 30 May to discuss funding in further detail.
The next IWG monthly meeting will be held on the 13 June. 

30 May 2024

This extra meeting was scheduled to supplement the Interim Working Group’s (IWG) initial discussions about funding for the Credit Reporting Governance Body (CRGB).

The IWG considered a set of funding principles and evaluated the alternative funding models used in the industry.

The secretariat team also presented a potential funding model for CRGB to the members of the IWG. The model proposed:

• an annual subscription fee for ongoing cost coverage
• a specific charge relating to CRGB’s set-up costs

The subscription fee is subject to a tiered system, split by industry stakeholder cohorts and tiers based on firm size.

The model was well received by a majority of the members. The secretariat team will now carry out more work to:

• validate the funding cohorts
• decide how much each cohort would be expected to contribute

The next IWG monthly meeting will be on 13 June at the Finance and Leasing Association offices in London.  

11 April 2024

This meeting was the first of several discussions about the second stage report topics, set out in the revised Terms of Reference (PDF)[31] on page 12.

The meeting began with the Interim Working Group’s IWG’s Legal Sub-group sharing their thoughts about the preferred method of incorporating the Credit Reporting Governance Body (CRGB) as a legal entity. The current view is that the CRGB would likely either be a company limited by guarantee or shares. The members agreed to seek input from the external legal advisors hired by the IWG to confirm the position and validate discounted options, about which incorporation vehicle the IWG should recommend to the FCA in its second stage report.

There were also discussions around governance principles, with a particular focus on the CRGB’s board structure. Further debate is needed on this topic, so the IWG Secretariat will be seeking individual written submissions from all IWG members about their views in the next few weeks.

Funding of the CRGB was also discussed. Initial views were shared, particularly around funding principles and what types of organisations would be expected to contribute to the funding of the CRGB. Potential funding models were also debated, with some members expressing an initial preference for a tiered membership model.

However, it was agreed that both the funding and governance models need to be explored in more detail before any substantive decisions can be made by the members. Therefore, the IWG Secretariat will work closely with the IWG’s Financial and Legal Sub-groups in advance of the next IWG monthly meeting to prepare in-depth proposals for further debate.

The members agreed and signed-off the first stage report sent to the FCA on 12 April and published on the IWG landing page on 16 April. The members will seek feedback on the first stage report with their cohorts and share this with the IWG’s Independent Chair and Secretariat team within the next month.

The next IWG monthly meeting will be held on 9 May at UK Finance’s offices in London. 
 

14 March 2024

The meeting continued work on the First stage report topics, set out in the revised Terms of Reference (PDF)[33] on page 10.

Significant progress was made and there was agreement about the Credit Reporting Governance Body’s (CRGB’s) purpose and objectives. The single sentence purpose will be complemented by three objectives:

• operational
• consumer
• future looking

The members expressed strong views about focussing the CRGB’s consumer objective on enhancing financial inclusion alongside wider consumer outcomes.

They also discussed and finalised the principles that would define the role of the CRGB. The scope of the roles was debated in more detail, with a particular focus on the scheme and any educational and/or policing role that the CRGB may be expected to play. IWG members were keen not to completely rule out roles that may be needed in the future.

There was debate about the types of datasets that will be relevant to the CRGB. An important distinction was drawn in terms of what data the CRGB may:

• govern directly
• have an interest in, as part of its wider role and remit

Before this meeting, 4 IWG sub-groups were set up with members focussing on the legal, financial, operational and engagement topics that the IWG needs to cover as part of its 9-month workplan as set out in the revised Terms of Reference.

The IWG’s engagement plan has been finalised and the secretariat team has already begun connecting with government and relevant regulators about its work. The IWG will soon host its first large event to engage with data users and contributors at the FCA’s London office on 26 March.

The next IWG meeting will be held on 11 April at the Finance and Leasing Association offices in London.

8 February 2024

This meeting was the first of several discussions about the proposed content of the IWG’s reports to be published and submitted to the FCA.  

This meeting focused on the first stage report (as set out in the revised Terms of Reference PDF[34]). Discussions were held about the potential purpose of the Credit Reporting Governance Body (CRGB), the stakeholders likely to be involved or impacted by the CRGB’s future work and the remit of the CRGB.  

The members agreed that CRGB should have a social purpose. It became clear that all were keen to place consumer outcomes at the forefront of the CRGB’s focus, alongside its role in supporting the effective sharing and use of credit information and related data.  

Before this meeting, members and secretariat developed detailed workplans for the first two reports and members took responsibility for delivering specified aspects. 

A communications plan has been developed, and will soon be finalised, to make sure the IWG engages effectively with industry including those cohorts not represented directly by the group. 

The next IWG meeting will be held on 14 March at the TransUnion offices in London. 

18 January 2024

The IWG formally convened on 18 January under the auspices of the Independent Chair. The IWG discussed proposed updates to the Terms of Reference published on the 5 December 2023 alongside the CIMS final report. In addition to reordering of outputs, the main change was the addition of a transition plan, from SCOR to CRGB, which will be subject to agreement with the SCOR membership. The group also discussed the inclusion of 2 addendums.

The first addendum covers the roles and responsibilities of the independent chair, secretariat team and members.

The second addendum covers the workplan and proposed timings for the publication of the IWG’s recommendation reports to the FCA as well as provisional dates for events to engage with wider industry.

The members agreed on the content of the addendums with suggested changes which provide greater clarity on responsibilities and sequencing of activities. Agreement was also reached on the updating and publication of the revised Terms of Reference. The FCA subsequently approved and signed-off on the revised Terms of Reference.

The IWG also discussed ways of working, including determining the locations for future meetings and industry events. The members agreed to prioritise, ahead of the next meeting, developing detailed workplans for the first two reports and assigning members responsibility for delivering on specified aspects of these workplans. The members also agreed to begin to develop a communications plan to ensure the IWG engages effectively with industry, particularly those cohorts not represented directly by the group.

The next IWG meeting will be held on the 8 February at the FCA offices in Stratford, London.

The IWG seeks to ensure transparency of its efforts. You can see updates of the IWG’s work, including events being held, on this webpage.

The Credit Reporting Governance Body, (CRGB) is the provisional name for the future governance body for the Credit Information Market. It will represent the interests of lender organisations, trade bodies, consumers and regulators.

The FCA Credit Information Market Study final report (PDF)[-37], published in December 2023, said that the industry governance arrangements need to be more agile.

The report also said that the proposed change will allow the organisation to more effectively respond to the evolution of the market and technology.

The IWG will only work on the governance remedy. The reform to the governance is seen as a key precursor to many of the other potential remedies that are proposed in the FCA final report. The IWG does not have a mandate to advance other remedies.

SCOR is the current governance entity and will continue to operate until a transition to the CRGB has been completed. IWG does not replace SCOR. IWG operates in parallel to SCOR with a different mandate.

CRGB will form the future governance for the Credit Information Market and a transition plan from SCOR will be delivered as part of the recommendations to the FCA.

The FCA and IWG outlined the scope and operational expectations of the IWG in their Terms of Reference (PDF)[35]. 

The FCA confirmed IWG membership to ensure a wide representation, appointed the independent chair to the IWG and provides secretariat support.

Feedback can be provided directly to IWG members, via [email protected] or during the industry events that will be held and published on this webpage in the coming months.

The IWG members are keen to make sure the thoughts of as may parties can be captured as part of the governance effort as possible.

IWG is an advisory body with no decision-making powers. It will make recommendations to the FCA on the design, implementation and operations of the new CRGB.

Any extension beyond the IWG’s 9 month programme, which started in January 2024, would need the approval of the FCA.

The IWG will work in a phased approach and has specific milestones to reach when reporting to the FCA.
 

Any recommendations to the FCA should have unanimous support among the IWG members.

Where this is not possible, the Chair should provide recommendations on a way forward and a ranking of options informed by the IWG’s discussions and based on the Chair’s own analysis.

Remedies taken forward through FCA rules will be subject to normal FCA consultation processes. Find out more about updates on CIMS[19].

The CIMS outlined a package of remedies categorised into 3 distinct types:

• FCA-led
• Industry-led
• Joint FCA and industry remedies (ie the CRGB)

The joint governance remedy is the first to be advanced. The reformed industry governance arrangements will be responsible for facilitating the thinking, development and implementation of the industry-led remedies. 

The FCA-led remedies will be advanced in parallel, with the remedies to improve data quality prioritised. The first steps will be to progress towards a consultation paper on rules for mandatory data sharing by the end of 2024.

The IWG recommendations to the FCA on the future governance arrangement will include a transition plan from SCOR to CRGB. This plan will include responsibilities and timing which will be agreed with the members of SCOR.