Publications

CAS has responded to HM Treasury's Consultation seeking views on the design and scope of the ban on cold calling for consumer financial services and products, including a call for evidence on the impacts of the proposed ban.

CAS has responded to the Equality, Human Rights and Civil Justice Committee's call for views on the Legal Services Regulation (Scotland) Bill.

In our response:

›     CAS reiterates our view that the Roberton model of a single independent regulator would deliver the greatest improvements for consumers in terms of transparency, accountability, and clarity of process. We underline our disappointment that the Bill has disregarded this model in favour of adding more layers of complexity to the existing landscape.

›     We express our disappointment that the promise of a regulatory regime with consumers at its heart does not seem to be delivered in the substance of the draft Bill – with many opportunities missed to strengthen the consumer interest.

›     We call for a clearer statutory role for consumer representation on the proposed regulatory committees (as distinct from generic lay representation), as well as consumer involvement in setting minimum standards for regulators.

›     We query the rationale for affording a lesser degree of scrutiny and accountability to current category 2 regulators in the draft Bill.

›     We welcome measures aimed at streamlining the complaints process including reducing complaints handling time, extending the remit to non-regulated for-profit providers, and introducing hybrid complaints. However, we caution that the retention of various layers and channels a complaint can take fails to deliver a simpler pathway for consumers, and we express concern about the removal of compensation for conduct complaints, as well as removal of the right to appeal SLSC decisions to an external body.

›     We welcome the expanded remit of the SLSC’s Consumer Panel but caution against the panel being seen as the catch all consumer scrutiny forum without increased resources to enable the panel to discharge these functions.

›     Regarding ministerial oversight, we call for greater consideration of the evidence sources for these interventions to be triggered, and the capacity this may require from the named bodies as well as consumer bodies fielding this data.

›     We call for urgent clarity regarding the definitions of ‘fee, gain and reward’, upon which third sector liability for entity regulation hinges. The variability of definitions of restricted and unrestricted legal services also poses concerns for the advice sector and we call for statutory consultation with these providers in the event of any change being considered.

›     We welcome the intention of the draft Bill to stimulate diversification in the legal services market, but we remain unclear how or whether the current provisions would enable this in practice. It remains difficult to envisage how the provisions around ABS and practicing restrictions might address the significant gaps in provision which CAS has repeatedly highlighted, without corresponding consideration of the pressing issue of legal aid reform.

To read our full response download here.

We have responded to the Scottish Government's consultation on how the mobility component of the new Adult Disability Payment is working.

On 14 March 2023, Citizens Advice Scotland's Strong Communities Team gave evidence to the Scottish Parliament Equality Human Rights and Civil Justice Committee's session on Access to Justice. This supporting evidence was submitted in writing afterwards.

Citizens Advice Scotland has responded to Ofcom's consultation on proposed changes to Ofcom’s NIS Guidance focusing on Incident Reporting Thresholds for the digital infrastructure subsector.

Citizens Advice Scotland is launching the Mental Health and Money Good Practice Creditor Guidance.  We've prepared this Briefing Note to support the launch.

We are actively encouraging creditors, both public and private to adopt our Principles. These set out the minimum standards someone experiencing mental health and debt can expect from their creditor when seeking support. Our guidance provides practical examples to firms and public bodies on how to achieve these minimum standards.

Debt is often the cause and consequence of poor mental health and wellbeing. This intrinsic link between debt and mental health is well known with it estimated that 1 in 2 people in problem debt also have a mental health issue.

Managing these issues can prove extremely difficult and people can often find themselves in vicious cycles where money problems impact upon their mental health and poor mental health worsens their financial situation.

Our Citizens Advice Network routinely supports people in these situations and with the rising cost of living crisis now being felt by our debt clients and beyond, we have seen countless examples of people with mental health and money issues reaching out to creditors seeking support, only to find barriers in their way such as inaccessible processes, online only options and a lack of understanding around their mental health.

These instances highlight the vast amount of missed opportunities to disrupt that vicious cycle. We believe that creditors, both private firms and public services can do more in breaking this link.

To do this effectively, it is crucial that creditors have the tools to support people struggling with mental health issues. Our Good Practice Guidance seeks to do just that by providing tangible steps that creditors can take to make them more accessible for those dealing with mental health and money problems.

By adopting our Principles, creditors can break this vicious cycle and care for their customers at a time when support for people’s mental health and money is needed now more than ever.

CAS has responded to the Scottish Government's Consultation on Improving Scotland's Social Security.