This is where it gets ridiculous. Under the agreed T&C's they may, subject to having given 28 days notice, change the T&C's. While there is no record of their having given any such notice, they have never-the-less changed the T&C's to the effect that failure on my part to complete an annual review entitles them to cancel the agreement
They now claim that I have cancelled our agreement, but there is no record that I have ever done so. On the other hand they have warned that unless I complete the annual review before some time in December they will exercise their right to cancel the agreement. But this raises the issue as to whether their failure to give the required notice had rendered the changes they had made to be without effect.
They say that completion of an annual review allows them to assess whether we can afford to complete the Debt Management Plan, and in doing so accord with FCA recommendations. Whereas I have argued that they are applying an overzealous interpretation of the FCA recommendations. In regard to which I note that according to an FCA enquiry "in some areas, an inaccurate interpretation or overzealous implementation of rules (such as those around data protection or affordability) is preventing firms from meeting the needs of vulnerable customers."