Buy to Let Mortgages

There are a number of missives shooting around the industry at the moment about Buy to let mortgages and the Consumer Credit Act. The latest I have seen is the one by BM Solutions which states something along the lines :

Credit Brokering refers to Buy To Let Mortgages that are not regulated under MCOB. 

Now that is interesting isn't it because the FCA have told us and as at five minutes ago on their web site continue to tell us :

The Government’s overall approach has been to keep the scope of consumer credit regulation broadly the same. There are no significant differences in the types of loan agreement that are exempt from being 'regulated agreements'.

But there will be some differences in the activities that are regulated. 

I think that the BTL mortgage market would be  termed as significant if it had changed.

The FCA then goes on to explain about Credit Brokering:-

The previous OFT regime, under the Consumer Credit Act 1974 (CCA), had two separate activities of:

• credit brokerage (introducing individuals to businesses that are lenders or other credit brokers)

• credit intermediation (certain other activities to arrange a loan)

To make regulation simpler for firms and consumers, the new regime brings together credit brokerage and credit intermediation in a single regulated 'credit broking' activity for which businesses will need to be authorised.

Now I could be wrong but I think that some of us are losing sight of the fact that the Consumer Credit Act is what we are talking about and that there are certain exemptions to the Act involving certain transactions on land. Along with regulated first mortgages, Buy to let mortgages are still one of those exclusions unless I have missed something important. So when we refer to Credit Broking as effecting an introduction of an individual to a lender  that results in a credit agreement , we have to consider the legal context. Of course, the Consumer Credit Act stipulates that only certain lenders can make use of this exclusion but I would have thought that all mortgage lenders would be  able to do so.

Furthermore we are told that under the Mortgage Credit Directive coming in in 2016, certain Buy to Lets will fall under regulation ( 'accidental landlords'). You cannot have dual regulation so something is wrong surely.

Finally, if we are looking at Buy to Lets falling under Consumer Credit Act, then presumably the same paperwork will be  produced as existing second charge mortgages. is that going to  happen - I don't think so because it would have had to be  in place already... cooling off periods and the lot.

However, there can be no doubt about it, if you want to refer BTL mortgages to BM Solutions you will need Credit Brokerage. If you are a client of mine, you will have already been told that for a number of reasons ( not including this one however).

No, in this period of festive cheer, this looks like a lot of administrative humbug, I respectfully suggest.

Will I have to eat my proverbial hat in the new year.?... Let's wait and see!

Consumer Credit VOP

For those of you who are currently going through the pain of the Variation Off Permission for Consumer Credit, here is a little thought to add to it.

There are exemptions on debt-counselling when it relates to the effecting of a regulated home finance contract and so technically you might not need to seek this part of the permission. However, the exemption does not apply to BTL mortgages at all, or to second charges until 21st March 2016 when the Mortgage Credit Directive takes effect.

I also have a concern regarding the wording of the exemption in those cases where you are unable to recommend a regulated mortgage to the client because they are ineligible with lenders yet your firm has undertaken some form of debt counselling... e.g "I recommend that you consolidate your debts into a single loan but I cannot recommend a mortgage to you." ( This is one of the examples in PERG 17)

However, if you apply for Debt Counselling you can possibly expect the full treatment from the FCA because it gives you the right to do all sorts of things. You don't necessarily want to have to explain your procedures and controls and so on for undertaking activities that you will never use and so the best way to deal with it is probably by including a non-standard limitation on your permission under debt counselling.

Just a thought in this run up to the festive season but if this remains unintelligible, please feel free to contact me.

An important issue relating to FCA Connect

I reported recently that firms were receiving emails from the FCA  to inform them that the had been set up as a new user of Connect to replace the ONA system.

What I didn't realise until Friday was that, according the the Firms Contact Centre (FCC), only those firms registered with ONA were getting these emails.  This does not necessarily create a problem for limited companies and partnerships where the owners of the company have Controlled Functions  and can therefore register online for Connect via the FCA  link here.

However, if you are a sole trader and have not registered for ONA previously, you will have a problem. You cannot register with Connect using the Controlled Functions route as you don't have any Controlled Functions and you cannot use the other option specified on the FCA Connect website because you won't have been provided with a Registration Key.

I spoke with the FCA on Friday and was told that the only way around this was to register with ONA first and then this would provide the migration route. I am about to test this out today with a firm and so I will be  able to report back on this hopefully tomorrow and will explain what you have to do to sort this.

I don't want to be responsible for unnecessary calls to the FCC, particularly as firms who have entered the window for CCL registration will need to use Connect to do so and so I recommend that if you are reading this and are a sole trader who has never registered for ONA ( or who has not had an email about Connect from the FCA) and are concerned, that you look out over the next couple of days for an update to my blog.

Mortgage Credit Directive - The Proposals for Disclosure (KFIs)

This blog looks at the KFI verses the ESIS and the proposed changes that may come in from 2016 until 2019 when the ESIS must be put in place by member states.  It also looks at some of the changes affecting lenders offers.

The Mortgage Credit Directive (MCD) requires firms to move to the European Single Information Sheet (ESIS) by 21st March 2019  where there is an equivalent national disclosure document in place. The KFI goes a long way to achieving this but additional disclosures will be  required covering :-

• information on the new seven day right of reflection period the MCD introduces

•  where applicable, extra information for foreign currency loans, including an illustration of the impact of a 20% change in the exchange rate and new rights introduced for foreign currency borrowers because of the MCD 

• information for consumers on the potential impact of interest rate changes, describing both the APRC and monthly payments should interest rates rise to the highest level seen in the past 20 years

I will not discuss these specific points in this particular blog although the last point will make some interesting discussion in relation  to affordability and the impact of potentially show stopping rates.

The FCA is proposing, in relation to the KFI, that these additional three bits of information can be provided at the same time as the KFI but on a separate document expressed in terms that are similar to the ESIS requirements from 21st March 2016 until 21st March 2019 for first charge mortgages. However, the same will not apply to second charges as there is no comparable disclosure in place and so the ESIS will apply to Second Charge loans from 2016 under the current proposals.

The ESIS is in prescribed form with little option other than to add certain additional information.

The FCA  is proposing to keep the current triggers (before an application is made) for the issue of the ESIS ( or its equivalent until 2019) even though the MCD requirement allows for disclosure at the time of offer at the latest.

On 21st March 2016 the  MCD implements a binding offer that is not conditional, supported by an ESIS. Under the MCD lenders will not be  able to issue a final offer that is conditional upon certain factors. This is a variation on UK lenders approaches. At this point in time I am unsure what that might mean for undertakings  and retentions or indeed self-build mortgages.

The FCA comments as follows:-

The MCD focus on there being a binding offer supported by an ESIS will mean firms need to review their approach to loans made available in stages (typical examples being self-build mortgages or mortgages with retentions). One possibility might be to make a binding offer for the full anticipated amount. The alternative would be to treat each tranche as replacing the previous loan, requiring a new ESIS each time. We have added guidance (see MCOB 6A 3.7G) to explain how a firm might approach the new requirement. 

Finally, for today's blog, there will be  a cooling off period introduced with effect from 2016 .  The MCD does not cover how the notice should be  given  but lenders will need to ensure that they can evidence this. There are two options available and the  FCA proposes the following:-

The binding offer is also the starting point for a new requirement for consumers to have time to reflect on the offer. This period has to be of at least seven days from the making of the binding offer and can either be a reflection period before entering the contract or a right of withdrawal after the contract. Member states have to choose one of these two options. We propose to require a compulsory pre-sale seven day period of reflection as this will be much less disruptive for property sales. In line with the directive, our draft rules also set out that the consumer can accept the offer at any point during this reflection period. 

Mortgage Credit Directive - Types of loans covered

This first blog on the Mortgage Credit Directive (MCD) is focused on setting out no more than the types of loans that are covered by it and those that are not.

Those loans that are excluded from it are as follows:-

• Lifetime Mortgages, believe it or not, are outside the scope of the MCD although they will of course continue to remain regulated by the FCA. One difference is that the MCD defines lifetime mortgages as any loan where interest is rolled up and no payment is made, regardless of the age of the borrower. The FCA will have to build this into its own rules. The MCD also puts beyond doubt  the fact that equity release loans requiring regular repayments of capital are not lifetime mortgages.

• Bridging loans are generally exempted from the MCD although the MCD apples a narrower definition of bridging that recognised in the FCA handbook. Some loans therefore that are currently classed as bridging loans under FCA perimeter guidance will fall under MCD from 21 March 2016.

• Credit union mortgages – an MCD exemption for credit unions allows the FCA to avoid imposing new requirements, but credit unions will still have to meet FCA existing rules. 

• Overdrafts lasting less than one month – while there are likely to be very few loans of  this kind it might be a useful exemption for some specialist lending, such as for secured overdrafts for high net worth consumers.

• Business lending is largely excluded from the MCD and the FCA  is making no proposals for change here.

Loans that will come into the MCD and therefore FCA regulation  include second and subsequent charge mortgages which the FCA already regulates under transitional arrangements following the transfer of responsibility for Consumer credit earlier this year.

Where products are excluded from the MCD, the FCA wants firms to be able adopt the MCD requirements voluntarily although it makes one exception to this.  Lifetime Mortgages must continue to follow the MCOB requirements for example in disclosure where the existing KFI must be  used rather than the ESIS (European Single Information Sheet) as they believe that the Lifetime KFI serves the customer better than the ESIS.

I note that Sharia mortgages and home reversion schemes ( the latter technically not a mortgage) do not appear to be  referred to in the FCA document and perhaps further clarification might be forthcoming.

FCA Connect

From today the FCA has a new online notification system. It is called Connect and it will replace the ONA system with effect from 1st October (today). If you have any notifications in the ONA system, I understand that you will have until 1st December 2014 to process them but you should check this with the FCA Firms Contact Centre.

Most notifications and applications will need to be  submitted to the FCA by this system although some will require paper submissions ( see below).

You will have to use Connect to submit the following applications and notifications to the FCA:

• Approved persons
• Appointed representatives
• Variation of permissions
• Cancellations
• Standing data

Some applications will continue to be submitted on paper, such as:

• Waivers
• Change in control

You should be receiving a notification that you have been set up as a new user shortly. I know that some firms have already received their email. 

If you are one of my paid up clients, please let me know when you receive the email and I will assist you in registering if you require it.

NOTE: Those of you who are due to apply for variation of permission for Consumer Credit will be  using this system to do so.

Consumer Credit Applications October 2014

It is 1st October tomorrow and this is the start of the three month window for applying for full permission for Consumer Credit Activities for quite a number of mortgage firms.  At the present time, unless you applied in the previous three-month window, you have interim permission for CCA activities.

The purpose of this blog is to update you on what you need to be doing between now and 31st December 2014 ( when the window ends).

Firstly, you need to find out whether  your firm has to apply between 1st October and 31st December.  You should already have received notification from the FCA about this. You would have received this several weeks ago. If you have not received a notification or if you cannot recall one and are unsure if this is your time to apply, you should contact the FCA through the Firms Contact Centre and ask them.

If it is your time to apply then you need to complete the appropriate form. Given that you are already authorised by the  FCA,  you will only have to apply for an extension to existing permissions. this means that you do not have to worry about whether you are applying for full or partial permission  or any of the other things referred to in the FCA webinar a few months ago.

For clarity the FCA says on its web page on consumer credit authorisation that :-

If a firm is already authorised to carry out financial services activities but wants to also offer consumer credit, it has to make a ‘variation of permission’. Use this form with our guidance notes.

(This is  set out under Step 5 of the procedure on their web page)

The extension to permission form is available here and the guidance notes are available here.

At the time of writing my understanding is that  the form can be  download and completed offline and then emailed to the FCA. I have  heard from one firm that it will be  possible to apply directly online from 1st October but I have not been able to verify this with the FCA at the present time and  will update the blog once I have established whether this is the case or not.

If you are one of my regular paid-up clients I will assist you in completing this form and so I will not go into the details in this blog. If you email me to confirm that you are ready to apply, I will make the necessary arrangements. If you are not an existing regular paid-up client and want assistance with the form I will be  happy to help you if you let me know. My email address is david.c.payne1@btinternet.com

The fee that the FCA charge for the variation of permission will depend upon the CCA activities you apply for and your turnover and is likely to be one of the following -   £250, £400 or £500. This is payable when you make the application - technically within 5 days of being contacted by the FCA for your  debit/credit card details. It is a one-off application fee and is not refundable.

I assume that going forward there will be  an annual charge for CCA authorisation much like the existing mortgage and insurance annual fee. I don't know how much that will be but I also assume that it will be  rolled up in your annual payment and will remain payable monthly.

New Competency Requirements - Don't Panic!

Just a quickie based on some early feedback about one particular anxiety.

The new competency requirements in the Mortgage Credit Directive will be  met by mortgage sellers as long as they currently meet the existing requirements e.g. CeMAP 1,2 &3 .No new requirements are going to be  imposed on mortgage intermediaries under the current proposals.

The new requirements will impact those persons who are involved in the manufacture of mortgages or granting credit. i.e within lenders.

Mortgage Credit Directive and Second Charges

The FCA announced yesterday that it would bring the regulatory requirements for second charge loans under the current first charge mortgage regulations with effect from 21st March 2016. It also announced plans to implement the Mortgage Credit Directive ( the European Legislation on mortgages that we are required to comply with).

The intention is to deliver much of the  MCD under existing rules although there will be  some substantive changes regarding disclosure and APR. A number of other changes will also be implemented including new knowledge and competency requirements, obligations for firms dealing in foreign currency mortgages and new levels of professional indemnity insurance.

I have not read the details in full yet and will publish more about this early next week. For now this is just by way of a heads up.

Consumer Credit - Update

Letters / emails are currently heading out to firms from the FCA setting out the date window during which you will need to apply for full permission to undertake Consumer Credit  activity. Of course at the present time, you should have  interim permission if you applied for it prior to 31st March ( and if you didn't you don't actually have  permission to carry out any regulated consumer credit activity)

The window is I believe about three months and in your letter the FCA will tell you that if you don't apply in that window you will lose your permissions. So it is important.

This blog is simply to pre-warn you of the fact of this action and if you have already received it to reassure you.

Firstly you cannot apply before your window opens and you must apply before it closes so make sure that you diarise this action because it may well be  business critical.

Secondly, there is presumably a cost to this but at the present time I have no idea what this might be.

Thirdly, I have to confess a slight confusion myself  on the simple basis that as mortgage brokers, unless you undertake secured and unsecured loans as well as mortgages, you are not using a great deal of the Consumer Credit Act. I therefore fail to see why a simple extension to permission as you have already applied for  would not suffice for full permission. So I guess that we will just have to wait and see what information comes in next.

However, don't miss the dates... you should have  been warned.

Culture? What culture.

I don't know. You look out for blogs on compliance and then ,like proverbial London buses, two come along at once.

You may recall moderately recently, probably in a recent FCA Regulation Round Up that there was some discussion and reference to looking at a firm's culture as a part of the way that they would be  regulated. I was asked by a client recently what exactly that meant and how could culture apply to a sole trader. It is a very good question. On the face of it, this may bring to mind a number of images : customer service culture - have a niyce da'ay (spelling deliberate to emphasise pronunciation) or things like Every Little Helps or ....it's got our name on it and so on.

However, it's not that and I suggest it can be best summarised as follows:-

Recently (over the past 18 months or so)  the FSA and then the FCA issued a survey to a number of firms, following on workshops on Risk Analysis. They were not just ordinary surveys, for those of you who seemed to think they were. They were, to coin a phrase, exactly what it said on the tin when they invited you to complete them and it said in bold letters something along the lines of "Notice of Regulatory Review" in the email or letter you received. BTW, as my children would say, if you failed to respond to one of these surveys you would a notice threatening enforcement action. That made them pretty serious.

In these surveys, firms were asked a large number of fairly intrusive questions about how they operated and controlled the business, the nature of the business they carried out and so on. The surveys lasted between 90 and more than 180 minutes depending upon firms.

Those questions more or less defined what the FCA mean by culture and in some respects they have set out their stall for small firms over the next few years in that survey. If you completed one of these surveys, you will already know where you are achieving and where you are falling down. If you didn't have  the opportunity, then i will be  providing a series of blogs over the next few months on the matters arising in it and suggesting how they can be  addressed.

But first, lets get MMR in place and working properly.

MMR 11th Hour Health Check

OK so tomorrow, the long awaited MMR implementation takes effect and the new MCOB rules come into force. I guess that now would be  a good time to check off a few points ready for those mortgage interviews tomorrow morning!

Firstly, and I say this because I have noticed that a few people seem a little unsure, MMR has no bearing on the insurance(ICOBS)  ( or for that matter, investment) rules. For insurances you are still required to issue an IDD or a suitably worded terms (ICOBS guidance on this) of business letter. You will already recall that oral disclosure was introduced some while ago when ICOB was revised and updated as ICOBS.

Secondly, it is worth pointing out that non-advised sales are extinct from tonight. The only options for mortgage sales are on an advised basis or on an execution-only basis and all staff selling mortgage products must be appropriately qualified or under supervision. In so far as execution only sales are  concerned, the FCA have made it quite clear that they expect these to be  the exception rather than the rule so any firms out there with only execution-only business models will need to think again (and before tomorrow).

Affordability of the mortgage by the borrowers passes , de jure,  from intermediary to lender at midnight tonight although , de facto, this has pretty much been the case since the downturn. However, do not underestimate the convolutions that some lenders may go to in order to satisfy the requirements now that they have to sign off on this point. If you have  not planned for increased processing times for mortgage applications then a) you obviously haven't transacted any business over the past three months  and b) you had better plan for it now.

Of course, whilst responsibility for affordability passes to lenders under MCOB, there are a couple of obvious and niggling points to consider. Firstly there is Principle 6 and TCF. If you recommend a mortgage ( or even if you allow a client to choose their own mortgage) and they cannot afford it, it is a pretty fair point that you have not treated them fairly and you will be  in trouble. Then of course there is simple negligence law. You have a duty of care in your dealing with your client and notwithstanding the fact of MCOB rules, you would be  in breach of that duty if a client, placing reliance upon you (even in the simple fact of processing it on an execution-only basis ) could not afford their mortgage then invariably they would suffer loss ( in arrears charges if not actually the loss of their home) and you could be  held liable for negligence. There are of course possible implications under the Mortgage Credit Directive when it comes in in 2016 but I don't think I'll go there today.

There is a risk that a blog on this subject could run on for ever and so I will for the sake of brevity, suggest what you should have  in place for tomorrow so that hopefully you can check these off.

1. Have you got the disclosure script prepared? You know, the one that says what access to market you have ( unlimited , all but not direct to lenders, panel and so on) and explains how you are remunerated ( i.e your fees and the fact that you get paid commission by the lender). Is it documented and does everyone involved already trained in it?

2. Have you changed your CIDD to reflect the new requirements or do you have  a terms of business letter to issue. Two points here:

• You don't have to issue a mortgage IDD anymore or any other such document for mortgages 
•  if you don't issue one, how will you satisfy Distance Marketing Requirements (DMD) if they apply to your firm and how will you make your clients aware of their right regarding complaints, the Ombudsman and the FSCS - this last point is not a requirement of MCOB but is surely  part of TCF.

I confess that I have  not managed to find a definitive copy of a new CIDD on the FCA site although I recall that a new version was promised after 25th April. In fact the one that I have found on their site still has the Services word in it.(If you know better about an update, please let me know because I feel a little frustrated over it)

3. Have you prepared your texts for inclusion where you issue product specific documentation to clients prior to the issue of a KFI, as you will now be entitled to do? I have suggested to my own clients that one catch all position is to include it in your footer of all your emails.

4. Have you taken action to ensure that you record a positive election by the client to add fees to the loan? To me this can only be a specific letter or declaration signed by each client and setting out the costs and implications of such action and their  reason for the election. I personally do not believe that the FCA intended this to be  included in the general series of questions in a fact find. Don't forget that you have to keep a record of this for a minimum of three years.

5. Of yes, don't forget that by definition minimum record keeping for mortgages is three years and not 12 months (for those of you hitherto doing non advised sales only).

6.Are you recording the appropriateness of your recommendation to the client under the categories set out by the FCA in their roadshows - they issued a single sheet document setting the questions for you at the roadshows) AND have you added to that the importance of assessing the possibility of a further advance(FA)  and the reason for non-take up of said FA. This is a key record. If you use suitability letters either of your own or from software, make sure that as a minimum, these 9 or 10 points are covered. 

(DON'T KNOW WHAT THEY ARE? Talk to me.)

7. For those of you who plan to offer direct to lender mortgages as well and where you can't issue a KFI, have  you got a structure for a reasons why letter ( because for these cases -where no KFI is issued) such a document is mandatory!

8.If you really plan to do Execution only mortgages, have you got all the documentation in place and do you have a documented policy on execution only  that includes KPIs on the level of business expected - I suggest over 2 standard deviations below the norm.

9. Have you updated your mortgage procedures? And don't forget to keep updated standard documents for a minimum of 12 months.

10. Have  you trained your staff and is this recorded somewhere in their T&C file?

11. What about your advertising. Have you checked that to make sure that you have  not got any obsolete statements about levels of service or scope of products ( not to mention any vestigial Financial Services Authority or FSA statements - I've seen a few recently - if in doubt have  a look at the small print - you know the stuff at the bottom of the screen that only compliance consultants and the FCA will look at!) 

OK that's enough I think for this blog ... one of my wordier but it is important. Please note that it is not meant to be all inclusive and it is only a blog. You need to check these things out against the FCA requirements to ensure that you are complying. 

As always you are always welcome to contact me via the blog but on this occasion, given that tomorrow is the day, I should warn you that I will be off the internet from around midday today until about 17.00 tomorrow.

Consumer Credit Final Rules

On Friday the FCA published their Final Rules on Consumer Credit regulation. They are , according to the FCA, pretty much unchanged from their original consultation and have the greatest impact on Pay Day Lenders  and Debt management Companies. It will have  little impact on most mortgage broker firms, unless they also undertake additional work in these two particular areas.


For payday lenders and debt management companies, the following key changes will be taking place:

• a limit to  the number of loan roll-overs to two
• a restriction (to two) the number of times a firm can seek repayment using a continuous payment authority (CPA)
• a requirement to provide information to customers on how to get free debt advice
• a requirement for debt management firms to pass on more money to creditors from day one of a debt management plan, and to protect client money

A technical glitch with Adobe on my system at the present time prevents me from being able to give a full update right now but I will be getting back on a couple of points later in the week. In the meantime, if you want to read further you can read the consultation paper here

Second Charge Lending

I am  hearing a number of things at the moment about second charge lending and so thought it might be  worth putting a few facts together.

Regulatory responsibility for second charge lending transfers to the FCA alongside other forms of consumer credit in April 2014, and that it will be treated initially in broadly the same manner as other forms of consumer credit lending (NOTE: Not first charge mortgage lending)

The initial transfer process and the requirements that will apply for second charge lending from April 2014 will be largely the same as those that will apply for other types of consumer credit lending. Existing firms with an OFT standard licence will need to notify the FCA of their desire to have an interim permission in order to continue second charge business from April 2014.  I am assuming that this is the interim permission that has recently been requested by most firms but I am not 100% confident of that point as I write this blog. I will get back on that point once I have established the details.

It is extremely likely that there will be further changes for second charge lending after the European Mortgage Credit Directive (MCD) is implemented and so this will invariably muddy the waters further.  The European Parliament approved the new rules on 10th December 2013 and so the impact of this must take effect in the UK by December 2015.

I have not yet looked at the MCD and I can feel another blog forming as I write - but not today! I think it is fair to say that it will have an impact on how second charge business is transacted but in reality it is not sensibly going to be  before December 2015, surely?

Consumer Credit Rebates

Many firms will already have received notification (and indeed cheques) in relation to rebates on OFT CCLs, given that the current regime is to cease after 31st March this year. however, some firms have not had these details ( or payments) and may be wondering what if anything they are entitled to.

The requirements are set out here in detail by the FCA but by way of a brief overview, please consider the following to see if you are likely to be  eligible or not. (Please note, this is just for guidance ... to be  certain read the requirements.)

• You must have paid an OFT licence fee for a licence issued or renewed on or after 1 April 2009 or you have paid a maintenance fee on or after that date.
• You must hold a standard licence or be the original applicant for a group licence that will still be in existence on 1 April 2014.
• Your licence would have expired or have terminated at least one month after 1 April 2014

There are a load of caveats included in the FCA / OFT rules for this but that is it in very broad terms.

The rebate you should get is based on the following rules:-

A x B / C where,

A = the amount paid to OFT in respect of the Consumer Credit Licensing Fee / Maintenance Charge
B=  the number of complete months remaining on the licence / charge
C= 60 (the number of months in five years)

NOTE: The figure in A will be  the amount that you paid less £140 (the Consumer Credit Jurisdiction (CCJ) levy to the Financial Ombudsman Service  - which is not refundable). There seems to be  a discrepancy on the FCA site about whether the CCJ is £140 or £150.

What if I have yet to pay a maintenance fee?

My reading of this is that you must ensure that if you are due to pay a fee to the OFT between now and 31st March, that you do so. if you do not, your CCL will lapse prior to 1st April and your extension to permissions with the FCA will not be  valid and you will have to make a fresh application ( with costs). If you do not make the payment you will fall foul of the rebate rules but then again if you are in this category you won't be  entitled to a rebate in any case and you won't have made a payment to be  rebated on. Obviously, this approach is only advisable if you are not planning to undertake CCL   activities after 31st March this year.

OF COURSE, YOU HAVE ALREADY APPLIED ONLINE FOR YOUR EXTENSION TO PERMISSION FOR CONSUMER CREDIT ACTIVITY AFTER 1ST APRIL...haven't you?

MMR Webcast

The FCA have just published some details about a Webcast on the MMR. This seems like a good thing to have a look at as it is based on the MMR Roadshows that were conducted a few weeks ago. Whether you went to the roadshows or not, it would be  worth having another look at what's coming in on 26th April, just to make sure that you are still comfortable with it all. You can log in here and ,I suggets, that given you are required to identify your firm in the access point, it would be  a sound and prudent thing both to do and to be seen to be doing.

Most firms should be receiving emails about this right now direct from the FCA, if not already received  but just in case you have not...