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.
Pension transfer advice – assessing transfer risk
Alistair MacDougall Compliance 2015, 2018, 2019, 2021, DBAAT, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
It has been well publicised that the FCA has aimed increasingly close scrutiny in the direction of firms that have been providing advice in relation to defined benefit pension transfers. Apparently caught off guard by the then Chancellor’s introduction in the Pension Schemes Act 2015 of what are generally called ‘pension freedoms’, the regulator has […]