On 3 November 2022, the FCA published a report on borrowers in financial difficulty following the Coronavirus pandemic – key findings. The report details findings from the FCA’s review of firms’ treatment of borrowers in financial difficulty after the pandemic and includes all areas firms must improve on.


Following the outbreak of the Coronavirus pandemic, the FCA put in place the Tailored Support Guidance (TSG) for mortgages, consumer credit and overdrafts, so that those experiencing payment difficulties, as a result of circumstances arising out of the pandemic, continued to receive appropriate support from their lenders.

The FCA reviewed firms’ policies and processes, and also spoke to them about their implementation of the TSG. The FCA published a report in March 2021 that detailed its findings from that review which found that firms had progressed well, acting quickly to build their capacity to support customers. The FCA also found risks that needed to be addressed. To continue this work and ensure firms were meeting the expectations set out in the TSG, and providing tailored help, the FCA launched the borrowers in financial difficulty (BiFD) project in Spring 2021.

This latest report draws on the work streams in the BiFD project. The project’s aim is to ensure firms are meeting the expectations set out by the FCA in the TSG and that they are providing tailored support to customers who are in financial difficulty following the Coronavirus pandemic.


The report provides that the FCA found examples of firms delivering good outcomes for customers – but others must do a lot better to support borrowers in financial difficulty.

Just 30% of firms, reviewed by the FCA, sufficiently explored customer’s specific circumstances, which meant repayment agreements were often unaffordable and unsustainable.

The FCA has already told 32 firms to make changes to improve the way they treat customers and so far, seven of these firms have voluntarily agreed to pay £12 million in compensation to nearly 60,000 customers.

The report highlights that, in order to improve outcomes for borrowers in financial difficulty, lenders need to focus on issues in these areas:

  • Engaging with customers. For borrower’s who had missed a payment, the FCA found that some firms did not do enough to engage with them. The FCA also observed instances where excessive friction or unreasonable barriers resulted in poor outcomes. The Consumer Duty sets out further the FCA’s expectations concerning the existence of unreasonable barriers to firms’ provision of support to consumers.
  • Effectiveness of conversations with customers. The FCA observed that the most common forbearance option used was an arrangement to pay. It did not see much use of additional options, for example reducing the interest rate or making more structural changes to customers’ arrangements, such as agreeing term extensions or periods of time paying interest-only. The FCA reminds firms that to assess whether discussions are effective and whether good outcomes are being achieved, firms should consider whether to adopt a quality assurance approach that reviews the end-to-end process, rather than focusing on individual interactions in isolation.
  • Helping customers to consider and access money advice and not for profit debt advice. The FCA expects firms to help customers understand what types of debt advice or money guidance are available. While the FCA found that most firms informed customers of sources of debt advice and guidance through their written and/or online communications, it found most missed opportunities to highlight the benefit of these services in telephone conversations.
  • Fees and charges. The FCA reminds firms that they should carefully consider their rationale for charging fees, focusing particularly on the impact this has on customers and whether fee charging is fair and cost reflective.

In the report the FCA has also included examples of the good and poor practice it observed, along with supporting case studies. The examples of good practices are to help contextualise how firms could approach certain issues but are not intended to be prescriptive.

Going forward

The FCA expects all firms to review the report and if necessary, remedy any past failings.

The FCA plans to consult on the future of the TSG, and that may include proposing changes to the FCA Handbook.