The FCA is now regulating consumer credit lending. Things have changed. You may be a lender or a credit broker. You may be indirectly involved because you offer your customers the option to buy using credit. We can help you navigate FCA authorisation and life as a regulated firm.
One size doesn’t fit all in the consumer credit sector, so we offer a range of services to suit different businesses and different budgets.
Firms which have a current Interim Permission and those who are new to the market will need to go through the FCA’s authorisation process.
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 prepare around 50 FCA applications a year and we’ve never had one refused. 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.
For small firms we’ve written a ‘Plain English Guide’. Aimed at Limited Permission firms (and also good for firms with a large network of smaller partners), it provides straightforward information about the process and what’s required in each section of the application.
Here is a taster: Understanding your Limited Permission Consumer Credit Authorisation application: The Plain English Guide. Give us a call to talk about how this might work for you.
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. Take a look at our Regulatory Immersion Day to get your firm ready for life in the FCA’s world.
The FCA makes no secret of its desire to raise conduct standards within short-term high-cost (‘payday’) lending and debt management firms in particular. But no firms will be immune from their intrusive approach.
If you’ve had contact from the FCA – other than in connection with your authorisation application – 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.
Health check review
It might help to have someone independent come in to find and fix any problems before they become widespread. 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.