Timetable And Forms For Full Authorisation - #ConsumerCredit #P2PLending

The FCA has published the application 'windows' during which various types of consumer credit and P2P lending firms can apply for full authorisation. 

The dates are in Table on page 9. They vary by type of firm and may also vary by region for some types.

The FCA will write to all firms with interim permission by 1 May 2014 to confirm their application period. You should contact the FCA if you have not heard by 15 May 2014. In the meantime, you should register for an online account with the FCA.

In my experience it takes at least 3 months to prepare an application for authorisation, as there is a lot of information to gather and/or summarise at the same time as running a business. The FCA has published an authorisation application checklist, some sample forms and guidance on the supporting documentation required. Note that if you a P2P lending platform or your are offering high cost short term credit (payday loans) or a credit reference service, you will also need to complete a detailed description of your IT controls, which you can download here. There are a few FAQs here. 

Top tip: make your application for authorisation a proper project and start the process of completing all forms and supporting documents on Day One - especially the application form, regulatory business plan and IT controls forms. Complete the forms in parallel, not one after another, as you may be waiting 3 months before each form is complete. I recommend nominating one person to oversee completion of the application documents and a separate person to gather and provide data.

Please note that the FCA has also published the relevant information sheets that must be sent to a consumer with any notice that they are in arrears or default (under section 86A of the Consumer Credit Act 1974). 

New OFT Guidance on Consumer Credit Licence Applications

The OFT has published guidance on how it proposes to handle consumer credit applications in the lead up to the handover of its consumer credit responsibilities to the FCA on 1 April 2014. 

Basically, if the OFT can't process your application by 31 March, it will pass it to the FCA to process in accordance with the FCA's requirements. 

If the OFT does grant your licence before 31 March, you will need to apply to the FCA for interim permission to operate until such time as the FCA asks you to go through a full FCA authorisation process (which will be some time before 31 March 2016).

If you plan to apply for consumer credit authorisation on or after 1 April 2014, the FCA has some FAQs here.

Applying For Interim FCA Consumer Credit Permission?

The Financial Conduct Authority is now open to receiving applications for interim permission to engage in consumer credit activity beyond 1 April 2014. Registrations prior to 30 November 2013 qualify for a 30% discount on the registration fee.

Here's the FCA's step-by-step guide; a timeline, which includes consultation on the regulatory details later this month followed by workshops around the country from October to March. There is also some information on being supervised by the FCA; and a note of the differences in the scope of the OFT and FCA regimes.

Here's the OFT's page on the topic.

There are some specific issues not covered in the material released to date. Most importantly, how do you apply where you will need interim permission, but you don't have a current consumer credit licence and your activities do not fit the OFT's current application form?