FCA Dear CEO letter – customers in persistent debt PD36

FCA Dear CEO letter: customers in Persistent Debt for 36 months (PD36)


  • Dear CEO letter: customers in Persistent Debt for 36 months (PD36); published by the FCA on 3 February 2020
  • The letter is signed by Philip Salter, Director of Retail Lending and Claims Management, Supervision – Retail & Authorisations
  • This letter is relevant to all firms impacted by having any 36-month persistent debt interventions for their customers.
  • The FCA has carried out a review of the approach of a collection of firms’ PD36 strategy and their readiness to meet their regulatory obligations. The FCA’s review has identified some areas of concern where it believes there is a need to confirm its expectations.
  • With the 36-month PD milestone approaching in February and March 2020 for credit card borrowers, the FCA is telling the CEOs of impacted firms to check their firm’s approach to ensure it is reducing persistent debt while treating customers fairly.


The FCA emphasised that it is important that firms are operationally ready to deliver their PD36 interventions in line with the FCA’s regulatory requirements.

Operational readiness should include consideration of the people, processes (including all communications) and systems impacts and requirements to deliver competent customer engagements.  

This Dear CEO letter contained many sections:

  • Background to persistent debt rules
  • Treatment of PD36 customers
  • Card suspensions
  • Operational Readiness

As part of its review, the FCA is evaluating the approach taken by some firms in following its rules on persistent debt. Where the FCA identifies poor practice, it will take swift action to ensure customers are being treated fairly and that the FCA’s rules are being followed.

Timeline with relevant dates to be logged on regulatory calendar

  • FCA Dear CEO letter published on 3 February 2020

Next steps

For any queries or to discuss further, the FCA asks CEOs to use their usual Supervisory contact.

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