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Consumer Credit

Consumer Credit
FCA Authorisation

Specialist regulatory support for consumer credit lenders, credit brokers, debt advisers, debt collectors, and P2P lending platforms serving UK consumers.

120+
Firms Authorised
98%
Success Rate
14 wks
Avg Timeline

Consumer Credit Regulatory Landscape

The consumer credit sector encompasses lending activities, credit broking, debt advice, debt collection, and peer-to-peer lending platforms. The FCA assumed regulation of consumer credit from the OFT in 2014, bringing significantly enhanced consumer protection standards.

FCA regulation has transformed the sector through the Consumer Credit sourcebook (CONC), introducing stringent affordability assessments, creditworthiness checks, and responsible lending obligations. The Consumer Duty further elevates expectations for fair value and customer outcomes.

Successfully navigating authorisation requires demonstrating robust affordability frameworks, comprehensive debt management procedures, and customer-centric business models that prioritize borrower welfare and financial resilience.

Typical Services

  • £Unsecured personal lending
  • Credit broking and intermediary services
  • Debt counselling and debt advice
  • Debt collection and debt administration
  • Peer-to-peer lending platforms
  • Buy-now-pay-later (BNPL) services

Required FCA Permissions

Consumer credit firms require specific permissions based on their lending or intermediary activities.

Lending

Providing credit to consumers through loans, credit cards, overdrafts, or other credit facilities.

Key Requirements
  • Affordability assessments
  • Creditworthiness checks
  • Responsible lending policies
  • APR calculations

Credit Broking

Introducing consumers to lenders or arranging credit agreements on behalf of customers.

Key Requirements
  • Lender panel due diligence
  • Customer best interests
  • Commission disclosure
  • Clear explanations

Debt Adjusting

Negotiating or varying the terms of a consumer credit agreement on behalf of the customer.

Key Requirements
  • Debt solution suitability
  • Fee transparency
  • Client communication
  • Creditor negotiation

Debt Counselling

Providing advice to customers about the liquidation of debts or debt management solutions.

Key Requirements
  • Qualified advisers
  • Free debt advice
  • Vulnerability support
  • DMP administration

Debt Collection

Recovering debts due under credit agreements, including in-house and third-party collections.

Key Requirements
  • Fair treatment standards
  • Forbearance procedures
  • Complaint handling
  • Vulnerable customer policies

Operating an Electronic Platform for P2P Lending

Operating a platform that facilitates lending between individual lenders and borrowers.

Key Requirements
  • Platform resilience
  • Wind-down planning
  • Investor appropriateness
  • Loan book management

Key Regulatory Requirements

Consumer credit firms must demonstrate compliance with CONC and Consumer Duty frameworks.

CONC (Consumer Credit Sourcebook) Compliance

High standards of consumer protection in all activities
Clear, fair, and not misleading financial promotions
Adequate explanations of credit terms and conditions
Pre-contract information and disclosure requirements
Responsible lending and borrowing principles
Post-contract information and arrears management
Fair treatment of customers in financial difficulty

Creditworthiness and Affordability

Comprehensive affordability assessments before lending
Verification of customer income and expenditure
Credit reference agency checks and credit scoring
Assessment of ability to repay without financial difficulty
Consideration of committed expenditure and essentials
Documentation and record-keeping of assessments
Continuous monitoring and periodic reviews

Consumer Duty Requirements

Good outcomes for retail customers throughout relationship
Products and services designed to meet customer needs
Fair value assessment including price and quality
Customer understanding through clear communications
Customer support appropriate to needs and characteristics
Avoiding foreseeable harm to customers
Enabling customers to pursue their financial objectives

Vulnerable Customers

Identification of vulnerable customer characteristics
Staff training on vulnerability and mental health
Flexible and sympathetic forbearance policies
Referrals to debt advice agencies where appropriate
Appropriate communication methods and language
Suspension of collections activity when needed
Extra support for customers with disabilities

Financial Promotions and Marketing

Clear, fair, and not misleading advertising
Prominent APR and representative example disclosure
Risk warnings for high-cost credit products
Responsible marketing not targeting vulnerable groups
Social media and influencer marketing compliance
Affiliate and introducer relationship oversight
Financial promotions approval processes

Financial Resources and Capital

Base capital requirement: £5,000 (limited permission)
Base capital requirement: £20,000 (lending)
Base capital requirement: £50,000 (P2P platforms)
Professional Indemnity Insurance as appropriate
Own funds calculations and ongoing monitoring
Financial projections demonstrating viability
Wind-down planning for P2P platforms

Common Authorisation Challenges

Issues we frequently help consumer credit firms navigate during the FCA application process.

Affordability Framework

Building comprehensive affordability assessment processes that satisfy FCA expectations. We provide detailed frameworks covering income verification, expenditure analysis, and decision-making criteria.

Creditworthiness Assessment

Demonstrating robust creditworthiness checks beyond basic credit scoring. We help implement multi-faceted assessment methodologies incorporating credit data, income verification, and behavioral analytics.

Vulnerable Customer Policies

Creating effective vulnerable customer identification and support frameworks. We develop comprehensive policies covering mental health, financial difficulty, and disability accommodations.

Debt Collection Practices

Establishing fair and compliant debt collection procedures. We implement forbearance frameworks, communication standards, and complaint handling processes aligned with CONC requirements.

P2P Platform Resilience

For P2P platforms, demonstrating operational resilience and wind-down planning. We create comprehensive contingency plans, investor protection mechanisms, and loan book management strategies.

Consumer Duty Implementation

Embedding Consumer Duty principles across all customer touchpoints. We help design products for target markets, assess fair value, and implement outcome monitoring frameworks.

How We Support Consumer Credit Firms

Pre-Application

  • Business model scoping and permissions mapping
  • Affordability framework design and implementation
  • Lending policy and credit risk framework development
  • Technology and platform selection guidance
  • Capital planning and financial projections
  • Senior Manager identification and recruitment

Application Preparation

  • Complete Connect application submission
  • Creditworthiness and affordability procedures
  • CONC compliance manual and policies
  • Vulnerable customer framework documentation
  • Financial promotions and marketing compliance
  • Complaints handling and dispute resolution

Post-Submission

  • FCA query management and responses
  • Senior Manager interview preparation
  • Additional information and clarification requests
  • Conditional approval requirements fulfillment
  • Post-authorisation compliance monitoring
  • Ongoing regulatory support and updates

Ready to Get Authorised?

Speak with our consumer credit regulatory specialists to discuss your FCA authorisation.