By Steve Conley
Founder, Academy of Life Planning | Member, Transparency Task Force
The recent appointment of David Geale as Executive Director for Payments and Digital Finance at the FCA — and simultaneously as Managing Director of the Payment Systems Regulator (PSR) — marks a significant shift in the UK’s financial regulatory framework. Geale’s role includes responsibility for the consolidation of the PSR into the FCA, as part of the government’s so-called simplification agenda for financial regulation.
While the announcement was made with optimistic overtones — citing efficiencies and better alignment — it raises profound questions for consumer advocates, legal observers, and victims of large-scale financial abuse.
A System Under Strain: The Mastercard Antitrust Case
The PSR’s current remit includes oversight of payment systems such as Faster Payments and Mastercard, the latter of which is at the heart of a £14–19 billion collective action lawsuit representing up to 44 million UK consumers. This class action, originally heralded as one of the largest consumer redress efforts in UK legal history, has recently seen setbacks in the Competition Appeal Tribunal (CAT), prompting concerns of a slow-motion collapse of justice.
Despite this, the FCA and Treasury statements remain silent on the implications of regulatory consolidation in the midst of such a monumental case.
Q1: How does this consolidation affect the regulation of Mastercard’s interchange fee liabilities?
Regulators have been dancing around these issues for years. The Solicitors Regulation Authority (SRA), for instance, is simultaneously tasked with regulating both consumer representation in the Mastercard proceedings and the Compensation Fund liabilities that have yet to be resolved. Such dual roles raise serious concerns about conflicts of interest — concerns that will only grow under a consolidated regime.
Ongoing Concerns About Card Fees and APP Fraud
According to PSR Chair Aidene Walsh, Geale’s role will include oversight of the “important work the PSR does, including on APP fraud and card processing fees.” However, without explicit reference to the real-world implications for consumers — including unresolved liabilities and redress in cases like Mastercard — these statements ring hollow.
Q2: How does the PSR’s “important work” reconcile with the unresolved litigation and concerns raised by consumer champions like Which?
Transparency remains absent. Which?, along with other advocacy groups, has raised concerns about exploitative card fees and systemic vulnerabilities that enable APP fraud. The public deserves clarity on how these efforts will be protected — or diluted — within a newly merged FCA-PSR structure.
Deafening Silence on a £19 Billion Failure
Q3: Why is there no mention of the potential collapse of the Mastercard consumer redress case — and what does that silence reveal about our regulators’ priorities?
When regulators avoid comment on a collective action worth billions — representing tens of millions of UK citizens — it’s difficult not to suspect a coordinated suppression of scandal. With evidence presented in the public domain at the CAT, silence is not a neutral act; it is complicity.
Escalating the Issue: A Role for Parliament and the Transparency Task Force
Q4: How can the Transparency Task Force (TTF) escalate these concerns to Parliament, and how can concerned parties support this effort?
The TTF exists to challenge regulatory complacency and bring systemic abuses into the light. Now more than ever, the TTF must have direct access to Parliamentary scrutiny, particularly through the Treasury Select Committee and APPGs on Fair Business Banking and Anti-Corruption. We call on MPs, journalists, and fellow advocates to help us submit detailed evidence and testimonies.
Those who wish to support the TTF can do so by:
- Submitting case studies and witness statements to be included in upcoming TTF dossiers.
- Engaging their MPs with letters calling for an inquiry into the consolidation of the PSR and its impact on consumer redress.
- Supporting our push for legislative reform that ensures independent scrutiny of high-value consumer abuse cases.
Final Thoughts: Consolidation Should Not Mean Concealment
The regulatory simplification agenda must not become a vehicle for erasing accountability. As millions of UK consumers potentially lose access to redress, the consolidation of power within the FCA must be met with greater, not lesser, transparency. If this is truly about efficiency and protection, then the public deserves proof — not platitudes.
Steve Conley is the founder of the Academy of Life Planning and a member of the Transparency Task Force. He advocates for financial justice, regulatory accountability, and consumer empowerment.
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Important questions have since been raised following the article, particularly around the broader implications of the FCA-PSR consolidation:
🔹 Regulatory conflict and transparency: Concerns have been highlighted regarding Which?’s dual roles in supporting victims of payment fraud and backing collective actions — potentially leading to conflicts of interest within a system already fragmented between commercial and regulatory redress routes.
🔹 Structural imbalances in redress pathways: Evidence suggests that schemes like Visa and Mastercard may bypass traditional ADR mechanisms by routing high-value consumer cases through the Solicitors Regulation Authority, which lacks the transparency, consumer duty, and Parliamentary oversight applied to the FCA or Ombudsman services.
🔹 Need for unified consumer representation: There is growing support for formal collaboration between consumer advocacy groups (TTF, Which?, Consumer Voice) to present independently evidenced abuse cases to Parliament under a single, robust reporting framework.
🔹 The role of the SRA as a shadow regulator: The rise in SRA involvement in financial abuse cases raises serious questions about accountability, especially in light of past scandals like IRHP mis-selling and the Post Office.
These issues demand greater scrutiny — and collective action. Transparency must now be matched by coordination.