Update Consumer Credit timeline 1 st April applied for interim - - PowerPoint PPT Presentation
Update Consumer Credit timeline 1 st April applied for interim - - PowerPoint PPT Presentation
Consumer Credit Update Consumer Credit timeline 1 st April applied for interim permissions 1 st May FCA will write to firms giving them a 3mth window for full applications Firms will be able to apply to vary their permissions and use
Consumer Credit timeline
1st April applied for interim permissions 1st May FCA will write to firms giving them a
3mth window for full applications
Firms will be able to apply to vary their
permissions and use the FCA connect service to do so
No further applications will be allowed after 31st
March 2016
By 1st May firms will receive written confirmation of their
application window
↓
Consumer Credit application window
Category
- f
business Sub- category
- f
business Region Group 1 North Region Group 2 London &
International
Region Group 3 Scotland, NI, South and East Region Group 4 Central
Credit Brokerage Broker (FCA authorised as Home Finance Firm ) From 1st Oct 2014 but before 1st January 2015 From 1st Oct 2014 but before 1st January 2015 From 1st November but before 1st February 2015 From 1st November but before 1st February 2015
Do I need a consumer credit licence?
Only transacts regulated Mortgages/investments
under FCA
Do not allow clients time to pay for services .
Do not refer clients to 3rd parties for consumer credit activities including debt counselling, adjusting etc. or 2nd charge lending
Only advise clients to consolidate their unsecured debts into a specific regulated mortgage contract
Do not advise on BTL mortgages
These firms are unlikely to need a consumer
credit licence
Do I need a consumer credit licence?
All other firms who advise on regulated
mortgages/BTL/Investments etc.
Refer clients to 2nd charge packagers or credit brokers
Refer clients to debt management firms where the firm only offers one debt management solution. (19 examples in PERG)
Allow clients to pay any fees due to them for services via monthly instalments or a regular on-going maintenance fee
Referring clients for unsecured or credit card finance
Carry out BTL mortgage business
These firms are very likely to need a consumer
credit licence and may have already applied for interim permissions
What type of permissions under Consumer credit do I need
Limited permission activities These firms present a reduced risk to the FCA, lower fees and shorter application process. Examples are; Consumer hire (tool/Car hire), credit broking where this is a secondary activity Motor dealership, retailers introducing clients to a finance provider. Full permissions activities These firms are likely to be the majority of Mortgage brokers examples are; credit broking where introducing clients to Lenders is a main business activity, debt administration, counselling, adjusting or collection
Decision tool on the FCA website
http://www.fca.org.uk/firms/firm-types/consumer-credit/authorisation/prepare
What is it going to cost me?
Based on Firms estimated income from
Consumer credit activities:-
£300 -£2500 Do Not include income from regulated
mortgage contracts
Paradigm are going to update website with a Consumer
Credit page “how to plan and prepare for consumer credit regulation”
Paradigm Technical Helpdesk have already sent out a
number of communications
Paradigm will offer further bulletins and support updates
- n Consumer credit
Visit www.paradigmmortgages.com and click on
Consumer credit or ring Christine to discuss further