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The challenge

Thistle Initiatives was approached for help by a firm looking to get itself authorised by the FCA as a credit reference agency under the terms of the Consumer Credit Act 1974.

Thistle Initiatives’ role involved standing alongside the client and guiding it through the many rounds of questioning it takes to secure a credit reference agency permission from the FCA.

The client also looked to Thistle Initiatives to help it draft and submit a wide range of policies tailored to its specific business model.

The solution

Firms seeking a credit referencing agency permission are currently experiencing particularly intense scrutiny from the regulator. Just how intense, is clear from the fact that this client had to go through seven rounds of questioning, with 219 new questions asked, and required to submit no fewer than 19 policies for scrutiny in the course of the application.

Thistle Initiatives’ extensive experience in assisting credit-sector firms seeking FCA authorisation enabled it to play an invaluable role in helping the client negotiate all the hurdles set in its path by the regulator. After preparing and submitting the initial application, Thistle Initiatives worked collaboratively with the members of the client’s team, guiding them throughout the process. Each time the FCA came back with queries or challenges, Thistle Initiatives’ expert consultants quickly arranged a call to go through each question in detail and plan exactly how the client should respond to avoid triggering alarm bells for the FCA. Thistle Initiatives’ deep immersion in the world of regulation means its consultants know exactly what the FCA is - and isn’t - looking to see and hear when assessing a firm’s suitability for authorisation.

The same applies to the design of appropriate policies on everything from anti-money laundering and wind-down plans to vulnerability and outsourcing. These documents are much more than simple templates and need to be closely tailored to the precise specifics of the applicant’s business model. The FCA will require firms to defend them against a barrage of challenges. Saying the wrong thing at any point can derail an otherwise sound application - hence the crucial importance of the huge amount of work Thistle Initiatives put into preparing the client’s people ahead of every interaction with the FCA.

The result

With Thistle Initiatives’ help, the client came through prolonged and intense regulatory scrutiny with a clean bill of health to secure the credit reference agency permission it was hoping for.

The application came in for a particularly vigorous challenge around the fitness of the client’s governance processes, the appropriateness of its structure for reviewing complaints, and the suitability of its proposed credit referencing model. Ultimately, Thistle Initiatives was able to help the client provide satisfactory responses to all the FCA’s challenges and allay the regulator’s concerns.

In the current climate more than ever, clients value Thistle Initiatives’ continuous hands-on involvement in helping them negotiate a safe path through the many challenges the process entails. Thistle Initiatives’ close engagement and support at every stage in the application process, helped the firm secure authorisation and start putting its business plan into action.

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