Consumer Credit

Consumer Credit

Consumer Credit

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The Consumer Credit Regime transferred from the Office of Fair Trading (OFT) to the Financial Conduct Authority (FCA) in April 2014. This change required all firms carrying out consumer credit business to become authorised and regulated by the FCA.

 

With the application period closing on 31 March 2016, most firms will now be expected to be fully compliant with FCA regulation, with the shift to being regulated by the FCA meaning that all areas of business becoming subject to a much more intensive regulatory regime.

 

The main changes to the way consumer credit firms will be regulated include:

  • A consumer outcomes focused regulatory approach
  • Key senior management to become approved persons and accountable to the FCA for the conduct of the firm. A further shift to this approach is the FCA have announced that all consumer credit firms will become subject to the ‘Senior Managers Regime’ (SMR) in 2018.
  • Firms will be required to comply with the FCA’s high level standards which include, Systems and Controls (SYSC), Principles for Business (PRIN), Treating Customers Fairly (TCF), Dispute Resolution (DISP) as well as having to ensure that adhere to the consumer credit conduct of business rules (CONC).

 

The application for authorisation is just the start of a firm’s regulatory journey. Firms must ensure that the regulatory framework they have shown in their business plans and applications forms, is fully embedded within the firm and the firm’s culture and remains appropriate to the regulatory activities carried out by a firm.

 

How Protiviti can help  

Protiviti have assisted a large number of consumer credit firms with their applications for authorisation, ensuring that firms have had a suitable regulatory regime in place, which is appropriately documented with relevant policies and procedures. Our experience of working with regulated firms across the financial services industry also means we have a deep insight into how the FCA monitors and regulates authorised businesses.

  • Application and Authorisation 
  • Documentation reviews and assistance with developing suitable policies and procedures
  • Conduct risk reviews
  • Corporate governance reviews 
  • Control framework testing
  • Compliance health checks
  • Assistance with implementation of the Senior Manager Regime requirements
  • General regulatory advice and assistance