Voluntary Application for Imposition of Requirement

WONGA GROUP LIMITED

CCl-IP-039350

To: The Financial Conduct Authority ("the FCA")

Wonga Group Limited ("Wonga"), as an authorised person with a permission granted under Part 4A of the Financial

Services and Markets Act 2000 ("the Act"), hereby applies to the FCA for the imposition of the requirement set out in

the Schedule below:

1. General

l.l.ln 2011, in response to formal Notices requiring the disclosure of certain information, Wonga provided the

OFT with documents some of which revealed that between approximately October 2008 and November
2010 Wonga, and certain other companies within its group, employed unfair debt collection practices.
Communications were issued to customers wnder the names "Chainey, 0' Amato & Shannon" and "Barker
and Lowe Legal Recoveries", giving the misleading impression that the customers' outstanding debts had
been passed on to a law firm (or other third party) with the threat of adverse consequences for the
customers if the debts were not repaid quickly. In fact, neither "Chainey D'Amato & Shannon" nor "Barker
& Lowe Legal Recoveries" existed as legal entities. This practice was adopted with a view to maximising
Wonga's collections by unfairly increasing pressure on customers. Charges were added to customer
accounts before and/or after these letters were sent out.

1.2. 1n April 2014, Wonga reported to the FCA that it had discovered certain unintentional system errors. These
errors relate to the calculation of customers' balances where the inputs to these calculations such as fees,
balance adjustments or the timing used to calculate interest were not consistently applied.

1.3. As set out in Section 2 below, Wonga is required to (a) conduct a consumer redress scheme overseen by a

skilled person appointed by the FCA under s166 of the Act as a result of the circumstances set out in
paragraph l.l.and (b) review the relevant systems to identify the extent to which customers have been
affected and undertake a consumer redress scheme accordingly with the aim of establishing who may have
suffered detriment and then paying such redress as is appropriate as a resu It of the circumstances set out in
paragraph 1.2.

2.
Requirement

2.1. Wonga is required to conduct a consumer redress scheme whereby it determines whether the unfair debt
collection practices described in paragraph 1.1 above caused detriment, loss or damage to relevant
customers (whether its own customers or those of its group companies).

2.2. Wonga is required to conduct a consumer redress scheme whereby it determines whether the
unintentional systems errors described in paragraph 1.2 above caused detriment, loss or damage to
relevant customers (whether its own customers or those of its group companies).

2.3. To the extent that Wonga establishes that customers have suffered detriment, loss or damage through the
exercise described in paragraphs 2.1 and 2.2 above Wonga must then determine what the redress should
be and pay the redress to affected customers.

2.4. The consumer redress scheme under paragraph 2.1 above will be overseen by a skilled person appointed by
the FCA under s166 ofthe Act.

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Tim Weller for and on behalf of Wonga