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Credit Case Study

As one of the UK’s largest providers of credit loans, this client primarily deals with High-Cost Short-Term Loans (Payday Loans). In light of the new regulations set out by the FCA, the client firm sought Thistle’s help in ensuring they were compliant with their regulatory obligations.

The Brief

In light of FCA regulation of the consumer credit industry, the client was looking for support to develop its training policies and procedures. The client was particularly looking for a review of its T&C systems and controls to identify any shortfalls in complying with the FCA regulatory regime in time to meet its FCA application window.

What We Did

Thistle conducted an initial gap analysis and review of the client’s current training & competence scheme, focusing on the firm’s training structure, policies and procedures for all lines of business it was engaged in.

We then issued the firm a report highlighting its findings, with particular emphasis on their weaknesses and outlining what we would expect a compliant firm to have in place.

Following this, we worked with the firm to develop a timeline through which any weaknesses would be addressed, with much emphasis on resolving all non-compliant issues within a month and dealing with all others on a risk-weighted basis.

The Result

One of the key issues identified was that the firm had a disjointed T&C process which varied between its different business streams with no consideration of overall group goals. Thistle worked with the firm to implement a clearer structure with a defined reporting system and review arrangement, building T&C from the top down.

This strategy provided a unified platform which was then adapted to each business stream working with the Learning Development Department and each business sector’s management team.

As a result, the firm developed and implemented a compliant training and competence scheme which met the FCA’s regulatory rules and guidance in time for their application window.