Transcript Our approach
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Getting FCA authorised
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Our approach Gateway is key Flexible for different size firms FCA approach High minimum standards Getting inside your business 2
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The journey for your firm OFT regulation FCA interim permission
FCA application
FCA authorisation 3
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Step 1 Now • If firms want to start offering consumer credit When to apply Your application period • If firms have interim permission • If firms miss this date, they will need to stop regulated credit activities 4
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The difference between a permission and the consumer credit licence (CCL) • There’s no longer a licence, and no longer categories A, B, C etc • The authorisation application is a fresh start and is unrelated to the CCL • Firms apply for ‘Part 4A permission’: and have to choose full or limited permission • Firms choice is based on the regulated activities they carry out (i.e. the type of business) : – Some activities mean firms have to choose ‘full permission’ – Some activities will allow firms to qualify for ‘limited permission’ 5
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Step 2: Decide the level of permission
Two categories of FCA permission
Full permission Limited permission
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How to decide the permission level 1 • Look at what credit business the firm does 2 • See how it matches FCA ‘regulated activities’ 3 • Check whether those activities mean full or limited permission 7
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Step 3: Prepare the application • • • Firms will need to give us detailed information about their business Firms may need to prepare their supporting information now even if they plan to apply in several months’ time Firms should review our website to see what we will ask them to include, then start collating the information now 8
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Examples of what we will ask for • • • • • • • Basic information about the firm How the firm is set up, who works there Who owns or influences the business (controllers) How firms make their money (business plan) How firms make sure their business keeps to our rules (compliance monitoring) Financial information The firm’s history and any ‘significant events’ we should know about 9
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Approved persons • Our approach is to ensure senior management responsibility • Having ‘approved persons’ is a key way to achieve this • Senior individuals in the firm will need to apply to be the approved person, and prove they are fit and proper • We will hold the person accountable 10
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Step 4: Apply • • • Most firms apply using our Connect online system We have help text within Connect and guidance forms you can download on our website You may need to send in a paper form if you are already regulated by us for other things 11
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How much it costs to apply • • • Firms will need to pay an application fee when they apply The fee will be a calculation based on how complex we think the application is and the consumer credit income We have put all firms into different complexity categories based on what they do: – Limited permission – – – Straightforward: eg credit broker Moderately complex: eg, lender Complex: eg debt management company 12
Application fee breakdown
Firm’s credit income
Up to £50,000 £50-£100,000 £100-£250,000 £250,000-£1 m over £1 million
Limited permission
£100 £500 £500 £500 £500
Straight forward
£600 £750 £1,000 £1,500 £5,000
Moderately complex
£800 £1,000 £1,500 £5,000 £10,000
Complex
£1,000 £1,250 £2,000 £7,000 £15,000 13
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Changing firm’s details during interim permission Firms details should be kept up to date through our consumer credit interim permission website: search “CCI” on fca.org.uk
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Ensuring a level-playing field • • All authorised firms will appear on our register Our enforcement team will seek out firms that carry on credit business without permission 15