Firms that currently hold a consumer credit licence (CCL) issued by the Office of Fair Trading (OFT) who wish to continue to provide consumer credit advice and/or facilities from 1 April 2014, must apply for interim FCA permissions. The deadline for applying for interim permissions is this Monday 31 March. Further information can be found here.
The FCA has recently issued Policy Statement PS14_03 which contains the detailed FCA rules that will apply. You can find this document here.
This also includes (on pages 250 – 266 in Appendix 2) what the FCA refer to as ‘perimeter guidance’. This helps to clarify whether or not firms are providing ‘debt counselling’ as part of their advisory process; if they are, then consumer credit permissions will be required. Please note that investment firms that do not provide mortgage advice cannot simply assume that they aren’t caught by the consumer credit rules. Please look carefully at the examples in PERG 17.7.
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Paul Jay Compliance assessment tool, Conduct, DB Pension, DBAAT, Defined Benefit, FCA, FOS, Pension, PI, Senior Manager, SM&CR, Switch, transfer
Most firms will have at least vague recollections of the FSA’s thematic review of pension switching and the report it produced in December 2008. It produced a flurry of activity, but as time has elapsed it has perhaps become a distant memory, despite the high volumes of replacement business that have been and continue […]