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.
Should clients take Abridged Advice?
Paul Caine Compliance 2018, abridged, DB Pension, FCA, MiFID, Pension, Pension Transfer, Switch, TCF, transfer
Assessing suitability has always essentially been based around the same overarching principles … The recommended product type should meet the client’s profile and needs? The actual product recommended should be the most suitable, taking account of features and costs. In relation to the second principle, the cliché about cheapest is not necessarily the […]