In Part One I wrote about the problem with the UK banking model and why it undermines the UK economy. In summary, banks need to lend to make their current account model work; this helps a lot of people, but for a huge swath of society it can be less beneficial, encouraging a debt mentality and a debt spiral that many will never escape, nor repay. Here in Part Two, I try to recommend what can be done to create a better model.
The bank debt model of subsidising the provision of personal current accounts (PCAs) through revenues derived from credit products, such as overdrafts and credit cards, is not evil, nor even bad. It just isn’t right for every customer. Indeed, it is arguable that for the 60%+ of people in the UK who earn only £400 per week at most, and who have little or no savings, it is not appropriate.
The solution is not more banks. As I have argued elsewhere, that strategy has not worked. Neo-banks have universally embraced the same old, lending-based, free PCA model, but within low-cost digital frameworks. More of the same, but done better. Cool, yes, but not the answer to this problem.
Equally there is no evidence (yet) of how neo-banks providing PCAs can become profitable, not least because of onerous regulatory and Basel III capital requirements. I have observed that regulation is in danger of having the opposite effect in this case. It may reduce, rather than increase, competition.
Free-market competition is one way to address this debt spiral problem, and the onus is on us, the new non-bank fintechs with innovative non-lending models, to break into this space and dismantle the entire tenet that PCAs cost nothing. PCAs do cost money (for the banks, the real figure is probably around £200 per year per customer).
But, because of the massive power of the banks, with six operators owning over 95% PCA market share, free competition can only thrive if the regulators move their focus away from reducing bank charges (which is self-defeating in many ways) on to prevention of cross-subsidisation. All those free accounts are subsidised by interest “foregone” by customers on their deposits, and overdrafts and related charges; the problem is that only half of customers use overdrafts. So this is unjust on the overdraft users, especially those least well-off, who subsidise those other, often wealthier, customers who don’t have overdrafts. It also appears to be an anti-competitive practice, in that it prevents new entrants with non-lending models from competing on a level playing field.
In other words, the banks need to be regulated into charging people for what they use, fairly, instead of overcharging some and undercharging others.
Don’t get me wrong – most banks would welcome this. They talk about the free banking model quite openly as the worst mistake they ever made (pointing the finger of blame squarely at Midland Bank, which introduced it in the late 1980’s). But try telling your customers that what they always got “for free”, they now have to pay for. And imagine the media storm. So instead, the banks are looking to the FCA to enforce a major policy change in how PCAs are charged. I have no idea if the FCA has the required courage, and we won’t find out until its PCA charging review is published in the spring of 2018.
If the FCA does act to stop this anti-competitive practice, then the banks will no longer have a commercial imperative to sell credit to their customers to subsidise the provision of PCAs. In turn, this would encourage competition by introducing a level playing field for new non-bank PCA providers. It would also reduce the commercial pressure for easy credit to those for whom it is really not beneficial for their long-term financial well-being.
That should, and almost certainly would, reduce consumer borrowing and bad debt, and in turn, this would help to reduce the UK’s dangerously high consumer credit balance.