Consumer Credit

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The Consumer Credit regime moved from the Office of Fair Trading (OFT) to the FCA in April 2014. There is a big shift in the way consumer credit is regulated under the FCA, and this is likely to require a number of consumer credit firms to review the way in which they operate.

Thistle Initiatives can offer assistance with direct authorisation and variation of permission with the FCA, as well as a range of compliance solutions – from planning through to implementation and ongoing compliance support.

Thistle Initiatives has a wealth of experience working with firms who undertake a variety of consumer credit activities, including consumer credit, credit brokerage and debt collection. Thistle Initiatives can assist firms requiring support during the transition period from April 2014 to April 2016 and provide on-going support beyond if required.

Areas that we can provide assistance with include:

FCA Interim and Direct Authorisation:

The deadline in which to register for an interim permission with the FCA has now passed (31st March 2014). Firms with an interim permission from the FCA will be informed of their allocated application period, in which they can apply for direct authorisation.

Firms who either failed to register for interim permission by the deadline, or need to alter their interim permission can apply for direct authorisation from the FCA from the 1st April 2014. Directly authorised firms that wish to increase their permissions to include consumer credit activities can apply to the FCA for a Variation of Permission (VoP). We understand that this can be a complex and time consuming process for firms, especially those new to the FCA’s regulatory approach.

At Thistle Initiatives our experience of managing a large number of FCA authorisations suggests that a well thought through application leads to a much faster and generally hassle free conclusion.

We can advise you on whether or not your firm needs authorisation – and with the Consumer Regime still being defined and finalised, this is not always clear cut.

Should you need to proceed with FCA authorisation, then we can assist you through what may feel like a complex process, enabling you to benefit from our specialist knowledge. This is where our vast experience comes in.

Thistle Initiatives can help you to ensure that particular questions the FCA expects answers to have been effectively addressed, as well as assisting in helping you with the questions that will arise throughout the process. By knowing who to talk to and what to say, we aim to ensure that your FCA authorisation process runs as smoothly as possible.

An application completed correctly can lead to authorisation quicker than you may think.

For advice on FCA Interim and Full Authorisation for Consumer Credit activities please call us on: 020 7436 0630.

Compliance Solutions:

The regulation of the Consumer Credit regime under the FCA is vastly different to the regime under the Office of Fair Trading (OFT). The requirements are more robust across a number of key areas such as:

  • • The Regulatory Gateway (Authorisation)
    • Supervision
    • The Rules
  • • Complaints and Redress
    • Enforcement

Thistle Initiatives offer a comprehensive range of compliance solutions that can help across a range of areas. We have experience in working with a number of consumer credit clients providing a range of solutions to meet their compliance needs.

As a starting point we can provide you with advice and guidance in respect of what the new rules are and what this will mean for your firm. We could provide bespoke guidance on what the FCA’s requirements will be for firms carrying out the various consumer credit activities.

As part of support, we can conduct a Systems and Controls Gap Analysis. This would help your firm identify if it has any gaps in its systems and processes that the FCA would expect under the new regime, and if so, provide compliance solutions to resolve these.

We also offer continuing support through an on-going compliance support service. This means we are able to provide your firm with support across a range of compliance areas, as and when your firm needs assistance, in addition to providing regular on-site audits to help ensure the firm is operating as it is required under the FCA.

If you are interested in speaking to one of Thistle Initiatives experts for a no obligation assessment of your compliance manuals, contact us on 020 7436 0630.

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