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Statement on PRCA Membership


Following reports of serious concerns around the PRCA’s internal processes, GK Strategy has taken the decision to pause our membership of the Association.

We joined the PRCA in recognition of our commitment to the highest ethical standards. Integrity is one of our core values as an agency and until we have seen the results of the review that is being undertaken, and are confident that necessary action is being taken, we can no longer support the PRCA’s processes and leadership. Our directors are former members of the PRCA Public Affairs Board and take our responsibility for the highest standards seriously.

We care about our industry and remain committed to our reporting via the ORCL register.


Louise Allen
CEO, GK Strategy

Scott Dodsworth
Managing Director, GK Strategy; former board member of the PRCA Public Affairs Board

Emma Petela
Director, GK Strategy; former Co-Chair of the PRCA Public Affairs Board

GK Monthly Insights

The GK Insights team goes through some of the previous month’s biggest policy developments, focusing on actions taken by regulators to help consumers through the current economic climate. For more information, please get in touch via

FCA provides update on switching in the mortgage market

Although the FCA chose not to make a major intervention into the mortgage market at the height of the pandemic, we wonder if the number of ‘mortgage prisoners’, might be giving the FCA cause for concern. Last year, the FCA announced that it would seek a ‘proportionate’ response. In other words, a solution for borrowers that would not be too onerous for lenders.

However, the FCA has recently released a statement on mortgage switching during the ‘cost of living crisis’, underlining the fact that approximately half of mortgages currently arranged on fixed rates expire in the next two years. Interestingly, the statement also highlights how many mortgage borrowers have paid comparatively low interest rates in recent years, on both fixed and variable rates – therefore, most will likely face increasing mortgage costs as base rates and the cost of new fixed or other incentivised deals increase.

The regulator has implored lenders and mortgage intermediaries to support consumers to consider their options and potentially facilitate switches to a less costly mortgage if it meets a consumer’s ‘needs and circumstances’.

The FCA has also set out its expectations for mortgage lenders, including giving borrowers in financial difficulty appropriate tailored forbearance. Crucially, this forbearance should consider the individual circumstances of the most vulnerable borrowers. Additionally, firms are expected to help those struggling with debt by directing them towards free debt advice or money guidance.

The FCA has stated that it will continue to track the number of borrowers who are not switching despite the prospect of saving more money. It’s not out of the question that the FCA could also assess the impact of increased costs where cheaper legacy deals are replaced with more expensive ones in a rising interest rate environment. This could lead to dialogue with firms in the mortgage sector to discuss future actions to ensure good consumer outcomes.

We should note, at this stage, that the FCA does not believe that significant regulatory intervention is required, or, at least, it has not said that an intervention is planned. The regulator noted that it thinks that pricing is generally transparent, and the structure of a mortgage product is well understood by consumers.

However, the FCA’s stance may not be ironclad. The impact of this month’s fiscal event looms large over the regulator. Sheldon Mills, who holds responsibility for regulation of consumer finance and competition, emphasised that the FCA is aware of the “upward pressures on mortgage rates” and the removal of certain products in the past week. There is mounting evidence that the FCA is increasingly focused on ‘outcomes’, which means that, in the future, the regulator may not give much leeway to mortgage providers, even if the current circumstances may be beyond their control.

Therefore, the FCA could well return to this issue, if the economic climate worsens or instances of consumer harm increase dramatically, and one would expect that it may adopt a tougher stance that it has done in the past.

FCA takes issue with misleading adverts for Buy Now Pay Later products

Buy Now Pay Later (BNPL) continues to attract the attention of the Financial Conduct Authority (FCA). The FCA has written to providers of Buy Now Pay Later (BNPL) products warning that advertisements must comply with standard financial promotion rules. The Financial Conduct Authority is concerned that some BNPL lenders are misleading consumers through their advertising, which may not notify borrowers of potential risks such as taking on debt that customers cannot afford to repay and the consequences of missed payments.

While conventional promotions by firms have received much attention in recent years, the more recent role of social media in the distribution of BNPL promotions presents the regulator with a familiar problem – preventing consumers from making poor financial decisions.

The FCA’s assertion that some collaborations with influencers could be taking advantage of behavioural biases, leading to impulse buying, is certainly reasonable. However, a ‘minor’ issue for the regulator is the fact that lenders and merchants do not need to be authorised by the FCA to enter into BNPL agreements.

Nevertheless, the FCA is still minded to act on the issue – a sign, perhaps, of the pressure it is under to intervene (rather than simply supervise) in certain markets, as a result of the ‘cost of living crisis’. The FCA has emphasised that the financial promotions of those unregulated / exempt agreements will still need to comply with certain regulatory requirements regardless (depending on who is communicating or approving the promotion). Crucially, this means that not only may unauthorised companies be seen to be breaching rules if they don’t have an authorised firm approve their financial promotions, but also that firms must communicate promotions in a way that is ‘clear, fair and not misleading’.

In terms of next steps, the FCA has stated that it will continue to monitor the BNPL market and act against individual firms found to be non-compliant. This is a development that should surprise no one, given the work that both the FCA and HM Treasury have undertaken to ensure greater regulation of BNPL products. The FCA also expects firms to follow the rules of its new Consumer Duty, highlighting the need for firms approving or communicating financial marketing to have understanding of FCA expectations and the ways in which the ‘cost of living crisis’ could impact consumer outcomes.

This may give the BNPL market cause for concern, as the FCA will soon expect all parties involved in sales to ensure that consumers understand the short and long-term financial implications arising from the purchase of their products. While larger firms operating in other areas of consumer finance, who use more conventional sales and promotions methods, have already taken steps to ensure compliance with the Consumer Duty, the BNPL market may be less prepared for the changes on the horizon.

CMA takes further action to protect leaseholders

At a time when all eyes are trained on the housing market, the Competition and Markets Authority (CMA) has continued to act decisively to help leaseholders. The latest development is that thousands of leaseholders who paid a doubled ground rent will receive refunds and that nine more companies will remove such terms from leasehold contracts. The regulator has also stated that many of those who paid a doubled rent will receive a refund – the move could impact over 5,000 households across the country. Crucially, the CMA’s action has been influenced by the view that these terms result in people being stuck in homes they cannot sell or mortgage – an issue that we believe could be exacerbated over the next few years, as homeowners currently on fixed rate mortgages look to re-mortgage.

Arguably, the most striking decision that the CMA has taken is to ensure the removal of contract terms which were originally doubling clauses but were converted so the ground rent increased in accordance with the Retail Price Index (RPI). However, when one considers the context in which the decision was made, the reasoning that underpins it becomes clear. The FCA is not the only regulatory body that has felt compelled to intervene more frequently to protect consumers; CMA decisions have also been trending in the same direction. The CMA’s multiple interventions, during the pandemic, on behalf of consumers purchasing airline tickets and holiday packages that would eventually be cancelled, is clear evidence of an emboldened regulator.

Once the CMA took the view that the doubling clauses were unfair to leaseholders, it was inevitable that the body would rule that all those effected will see ground rents remain at the original amount when the property was first sold. Notably, this amount will not increase over time and the freeholders involved have also agreed to refund residential leaseholders who had already paid out under doubled ground rent terms.

We do not expect the CMA to relent on the issue, given that its investigation into the leasehold sector, began in June 2019, and now spans three governments. There’s remains a significant amount of political will, amongst MPs and campaign groups, to see whether (or the extent to which) there have been breaches of consumer protection law. As the investigation has at this juncture, identified the escalation of ground rents, potentially harmful sales practices, excessive service / permission charges and a lack of checks and balances as key issues to address, it is unlikely that the CMA will face any political pressure to wind down its activities.

The Pensions Regulator addresses refinancing in the current economic climate

The Pensions Regulator (TPR) has also given thought to the impact of the UK economic woes. The regulator has also set out its expectations of pension trustees and sponsoring employers when refinancing, imploring relevant parties to take stock of the worsening economic climate. David Fairs, the Executive Director of Regulatory Policy, Analysis and Advice at TPR, has stated the new macroeconomic challenges that country could face in the coming months may make refinancing even more challenging for sponsoring employers, as many organisations look to recover from the pandemic.

After the disruption of the pandemic, the gradual return to a more familiar business environment was always likely to result in the return of refinancing in a more traditional sense. However, the growing economic uncertainty in recent months, has led TPR to list several things that employers and trustees should consider, as they could have a tangible effect on the employer covenant. These include interest costs and fees, as changes in the cost of debt could impact an employer’s ability to meet pension contributions and debt structure, with the regulator noting that trustees should command a good understanding of any impact of replacing one type of debt with another.

Additionally, trustees are expected to consider financial covenants – typically measures of company financial performance that, once breached, allow debt holders to act, such as calling in their debt, charging a fee, taking security or otherwise make commercial improvements to their terms. TPR believes that changes to such covenants could represent a power shift between trustees and lenders in the event of financial stress.

In truth, trustees and employers will already be aware of these issues, however, TPR is likely to continue to voice its concerns this autumn. Despite the resilience one can find in certain markets – such as asset-backed lending – TPR has noted that credit conditions are tightening and larger refinancings have become more challenging, having been impacted by lender concerns around certain sectors and ensuring adequate returns on their investment.

The regulator has taken the view that these conditions are likely to be reflected in higher interest rates and tighter covenants, with potentially more onerous security requirements and greater restrictions on use of funds. An important counterpoint, however, is TPR’s admission that the rise of alternative lenders, including hedge funds and private equity, alongside newer retail banks or ‘challenger banks’, may help to ensure that liquidity remains available to sponsoring employers.

Ultimately, TPR’s key desire is for sponsoring employers and trustees to understand the implications of any refinancing on pension schemes and the employer covenant, and to go reasonable lengths to mitigate any damage that may be caused by refinancing – again, this should not be a surprise. The reality is that TPR’s messaging is similar to the other regulators that we have already mentioned. As the ‘cost of living’ bites and the Government attempts to enact its reforms, the intentions and context underpinning decisions made by organisations may become less relevant. Instead, the FCA, CMA and TPR are likely to focus on the material impact of any decision made by an organisation on individuals.

gk Coronavirus reveals the unsustainability of the Government’s devolution dualism

What’s in store for the levelling up agenda now Liz Truss is Prime Minister?

GK Researcher, Tristan Robinson, investigates what’s in store for the levelling up agenda under the premiership of Liz Truss and whether tangible progress can be delivered before the next general election.  

What we know so far 

During the Conservative Leadership Contest, Liz Truss never truly went into detail as to how she’d take on levelling up under her premiership.  

She had often used the term levelling up in a “Conservative way” by focusing on tax cuts, deregulation, and devolution to boost growth. The recent not-so-’mini’ fiscal statement set out by the Chancellor of the Exchequer Kwasi Kwarteng, has given a clear indication that Liz Truss has kept with her mantra of governing in a ‘Conservative way’ – Trussonomics. The Chancellor gave no mention of levelling up in his speech but did announce the creation of new ‘investment zones’ in over 4o locations across the UK. It’s hoped that this would encourage businesses to invest by incentivising lower tax regulations and planning rules. If some of these new ‘investment zones’ were selected in areas such as Liverpool, Teesside, Newcastle and Grimsby, the financial benefits for the local areas could be significant.  

Andy Street, Mayor of the West Midlands recently outlined his support for targeted Investment Zones whilst Mayor for Tees Valley Ben Houchen called it a ‘gamechanger‘ for areas such as Teesside, helping to rejuvenate town centres such as Hartlepool and creating new high-wage jobs. Yet, it remains unknown as to how long it will take for these zones to be implemented. In addition, there is a possibility of opposition from the Government’s own backbenchers who are concerned about losing their leafy rural seats that have long been opposed to development.  

Liz Truss has also pledged to reverse the decision to downgrade the Northern Powerhouse Rail project which links Liverpool with Hull, stretching across England. During the contest she did not commit to completing the HS2 Line between the East Midlands and Leeds. It is yet unknown whether she will go through with this decision and reverse the downgrade and commit to the Eastern Leg. She also committed to Northern Research Group pledge card that aims for further devolution, a Minister for the North with direct responsibility for local growth and levelling up, the equalising of the Levelling Up Formula and introduction of two new vocational institutions in the North of England.  

Levelling up is not just about infrastructure & transport, and Liz Truss has yet to go into detail on how she will help level up the UK by fixing the social disparities on matters such as quality of education, access to health care as well the quality of living between the North & South of England.  

Time is ticking…  

Liz Truss has not made levelling up her flagship policy for her administration, but rather tax cuts & deregulation. Whilst she has given an inkling as to what her approach would look like – such as introducing new investment zones & supporting the Northern Research Group pledge card – she has yet to give a detailed plan on what their levelling up agenda would look like or how long their proposals would take to implement.  

The immense cost to level up makes it near impossible to do anything substantial in a short time frame and with many Southern MPs concerned of losing their seats on the topic of development, illustrated with the impact of the 2021 Chesham & Amersham by-election which ultimately caused planning reforms to be ditched during Johnson’s premiership. Centre for Cities believes that to truly level up and close the North-South divide would cost £2 trillion and would take decades to implement long-term efficient policy. In truth, Liz Truss will have very little time to fulfil any substantial changes to the geographical disparities in the UK in under two years. The incoming winter crisis & the rising tensions with Russia will inevitability shift the focus away from levelling up just as Covid-19 had done for Johnson’s government.  

Labour’s Alternative 

Shadow Minster for Levelling Up, Lisa Nandy, introduced an alternative with a 5-point plan to level up the UK. Focusing on jobs, Labour wants to spread job opportunities across the UK by investing £28bn each year in green projects in industrial and coastal towns. The plan also wants to set off 100k new businesses to help local high streets, and includes fostering greater connectivity with towns and villages by investing in better transport and digital infrastructure, more devolution, and reintroducing neighbourhood policing to ensure town centres are safe. 

As Labour Conference rumbled on and Labour revealed more of its outlook in the run up to the next election, Labour’s Shadow’s Transport Secretary Louise Haigh offered a telling insight into Labour might tackle the problem of connectivity. Haigh promised not just to nationalise the railway system once more, but to build a Elizabeth Line for the North and deliver the Northern Powerhouse Rail and HS2 in full. Lisa Nandy also spoke at Labour Conference at an event with the Conservative-led thinktank Onward pledging to boost building of social housing and “finish the job” on rebuilding northern cities that was originally planned during the last Labour government.  

GK Strategy are experts in helping organisations to understand the changing political landscape, and strongly recommend that business leaders quickly meet with government to discuss their priorities. For more information, get in touch with