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.