Hard to tell without the full 30/60/90 day background and a...

Hard to tell without the full 30/60/90 day background and a better understanding of impairments vs actual losses. I'm sort of trusting the short history FSA has with personal loans, in conjunction with Tim's prudence (and massive self-interest) to save the day here. 

For a very relevant comparison, check MNY. Specifically, page 52 of their annual report. Approx. 62m of the 240m odd car loans are on the 'Watch List', which have a 'moderate chance of default'. In my mind, this would be almost equivalent to 30day arrears, but not quite there. Either way, if 25% of your book has a 'moderate chance' of defaulting, it makes FSA look like a prime lender. Not to forget the finance costs MNY 9%, and it costs FSA a lot less.


@LuckyBloke - regarding Recommendation 8, the informal debt agreement structure allows for up front fees, only the formal ones do not. 
Given home owners now make up the vast majority of formal debt agreements now (after the 5yr to 3yr change), they're far more likely to refinance their home and agree to an informal agreement, allowing the model to go unchanged.