The regulation of consumer credit lending moved from the OFT to the FCA. For many firms this was their first experience of the principles-based regulatory structure of the FCA. A regime that some found very different to the OFT. We supported many firms through this transition period, as they submitted their applications for authorisation to the FCA, and moved from interim to full permission. We are still helping firms navigate the regulatory environment, and ensure they are delivering good outcomes for their customers.
The transition from interim permissions to full FCA authorisation has now been completed, and all consumer credit lending firms previously authorised by the OFT should be FCA authorised. But there are still firms looking to enter the market, who need advice, and existing firms looking to vary their permissions.
There are two different types of firm – Full Permission and Limited Permission. The type of firm you are depends on the activities you carry out. Both types will need to go through the authorisation process. This is more than simply filling out forms – you need to meet the ‘Threshold Conditions’ – minimum standards for FCA regulation. You’ll also need to demonstrate that you’ve the necessary systems and controls in place, robust compliance procedures and the right culture to ensure the fair treatment of customers is at the heart of your business. The authorisation process is complex, even for Limited Permission firms. Don’t underestimate the amount of time and effort required to prepare and submit an application.
We’ll work with you to prepare the supporting documentation – including your regulatory business plan. We can give advice on the application of the rules, review your existing documentation, help you design new processes, or manage the authorisation process from start to finish. Whatever you need.
FCA authorisation was the beginning of the journey, not the end. Many firms seek our support to assess whether they are continuing to operate in line with the procedures set out in the Regulatory Business Plan, they submitted to the FCA. We can carry out an independent assessment across all FCA regulatory areas. Interviewing staff at all levels from the Chief Executive down. We’ll assess whether your processes meet the requirements, by reviewing the customer journey from start to finish. We can provide feedback on such areas as your affordability checks, or your arrears handling process.
Your people are your biggest asset. We provide bespoke training to help them understand what’s expected. We’ve helped lots of senior managers prepare for their roles as Approved Persons as well as designing and delivering training for operational staff.
Credit lending regulatory intervention
The FCA makes no secret of its desire to raise conduct standards within short-term high-cost (‘payday’) credit lending and debt management firms in particular. But no sector will be immune from their oversight.
If you’ve had contact from the FCA we can help you. From coaching staff who may find themselves about to be interviewed by the regulator to helping you set the right tone in written communications or responses to information requests.
The fair treatment of customers is a central pillar of the regulator’s regime. We can help you tell whether your current practices are up to scratch and implement any cultural changes needed to meet their expectations.