The challenge
Thistle Initiatives’ specialist Credit team works with a wide range of firms in this dynamic and fast-evolving sector. We’ve helped many fledgling credit firms turn their business plans into FCA-authorised businesses. It was on the recommendation of one such client that we were first approached by another credit firm looking for compliance support and advice.
When we first started talking, the firm’s business plan remained very much a work in progress. Their small team included several individuals with expertise in the price comparison arena, and they had identified an opportunity to provide a service enabling consumers to see what types of credit might be available to them.
The plan was to access open banking data to enable a sophisticated, powerful but above-all user-friendly credit comparison service - potentially crossing over into some form of credit broking activity or advisory service. Its founders recognised the opportunity but lacked the specialist knowledge to understand how to put their ideas into practice from a regulatory point of view.
The solution
The first substantial aspect of our involvement involved mapping the firm’s proposed activities against current FCA regulations to understand precisely which combination of FCA authorisation, permissions and exemptions would be required to put these plans compliantly into practice.
Having carried out this initial assessment, we went back to the client with a detailed advice paper, which then formed the basis of further discussions aimed at refining its business plan and scoping the work required to secure the necessary regulatory approval.
Being involved right from the outset of the firm’s journey gives us a unique opportunity to help shape the path a firm sets out on, applying our sector-specific regulatory experience and insight to give it the best chance of realising its ambitions swiftly and compliantly.
In this instance, our input resulted in a decision to step back from the very broad suite of permissions the firm had originally intended to apply for, and to focus on something more closely defined and specific. By helping the client structure its operations intelligently, we were able to minimise the regulatory friction that could otherwise have slowed or complicated the process of securing authorisation.
Refining the new credit firm’s offer helped ensure it would achieve its core objective of getting up and running with an attractive and viable proposition, rather than hedging its bets and attempting to be all things to all people. We know from experience that the FCA is always likely to take a more positive view of applicants with a focused and coherent approach, than those looking at something broader and more speculative.
The next stage in our engagement was working with the firm on its application, ensuring everything was put together to give it the best chance of securing the FCA’s approval, and that all the relevant supporting materials were in place. We then helped them field and respond to follow-up enquiries from the FCA, smoothing the path to regulatory approval.
The result
Because of all the careful work we had done in advance, the client was well-prepared to respond with watertight arguments when the regulator queried the rationale for which permissions it believed it did and did not require. Across the initial submission and all subsequent discussions, the firm was able to convey the reassuring impression of being fully across and the detailed requirements of applicable regulation.
Thanks to Thistle Initiatives’ involvement, the client was able to perfect its plans and put them into practice - within a matter of just a few months - through a focused and efficient FCA-authorised vehicle that’s already proving itself in the marketplace.
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Contact us on 0207 436 0630 or email info@thistleinitiatives.co.uk.