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BCC runs compliance for consumer credit firms regulated by the Financial Conduct Authority (FCA): lenders, brokers, debt collectors and debt management firms, with full or limited permission.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
The short answer
A UK consumer credit firm must meet the FCA's Consumer Credit sourcebook (CONC), the Consumer Credit Act 1974, the Consumer Duty, the Senior Managers and Certification Regime (SM&CR), complaints rules and consumer credit returns. A consumer credit compliance consultant tests lending, collections and promotions against these rules, fixes the gaps and provides ongoing monitoring or outsourced compliance roles.
Consumer credit is one of the FCA's most closely watched retail markets, because the harm from poor lending decisions and poor treatment in arrears falls on customers who can least afford it. Firms are authorised under the Financial Services and Markets Act 2000 (FSMA) with either full permission, for lending, debt collection, debt management and similar activities, or limited permission, for lower-risk activities such as some secondary credit broking.
The core rules sit in CONC: financial promotions in CONC 3, pre-contract information in CONC 4, creditworthiness and affordability in CONC 5.2A, persistent debt in CONC 6.7, and arrears and forbearance in CONC 7. These operate alongside the Consumer Credit Act 1974 and the Consumer Duty. The FCA tests firms on outcomes: whether lending was affordable, whether customers in difficulty were treated fairly and whether prices represent fair value.
Consumer credit firms are within SM&CR as core or limited scope firms. Senior managers must be approved by the FCA before they start, have a statement of responsibilities and, for core firms, hold prescribed responsibilities. The firm must certify staff in certain roles as fit and proper each year and train all staff on the conduct rules. Which senior manager functions apply depends on the firm's category and permissions, so the first task is to confirm the category and map responsibilities against it.
Part 12 of FSMA and SUP 11 in the Supervision manual set out when a person acquiring or increasing control of a regulated firm must obtain FCA approval in advance, and the FCA has up to 60 working days to assess a complete notification. Lenders and brokers are regularly bought by private equity and by larger groups, and the position for limited permission firms differs, so we confirm which rules apply and prepare the notification and controller documents.
Consumer lenders are generally within the Money Laundering Regulations 2017 (MLRs) and must carry out a business-wide risk assessment, customer due diligence, ongoing monitoring and suspicious activity reporting, with a nominated officer, the money laundering reporting officer (MLRO), under regulation 21. Many credit brokers and debt firms are outside the MLRs, but every FCA firm must still counter the risk of financial crime under SYSC 6.1.1R of the Senior Management Arrangements, Systems and Controls sourcebook (SYSC).
In lending, the practical risks are application fraud, identity theft, synthetic identities and the use of loans to move criminal funds. We review the firm's onboarding and fraud controls, test a sample of files, check whether the risk assessment reflects the firm's real channels, including brokers and online journeys, and write the MLRO annual report. Where the firm needs one, we provide the MLRO.
The policy set for a credit firm must cover lending and affordability, financial promotions, arrears and forbearance, vulnerable customers, complaints, outsourcing and broker oversight. The FCA reads these policies against outcomes data, so we write them to match the firm's actual decision rules and collections process.
The Consumer Duty in PRIN 2A has had particular impact on credit: fair value assessments of interest rates, fees and add-on products, support for customers in financial difficulty, and communications that customers understand. The board must review and approve an assessment of outcomes at least annually. Complaints must receive a final response within eight weeks under DISP 1.6.2R of the Dispute Resolution sourcebook (DISP), and complaints data should feed back into product and collections changes. We build the fair value assessment, the outcome metrics, the board report and complaints root cause analysis.
A compliance monitoring programme turns rules into tested evidence. For a lender, testing should cover affordability decisions, financial promotions, broker oversight, arrears handling, vulnerable customer treatment and complaints, with findings reported to the board and tracked to closure.
Consumer credit firms submit data items to the FCA through RegData. The FCA's consumer credit reporting includes CCR001 financial data, CCR002 volumes, CCR003 for lenders, CCR006 for debt collection, CCR007 for all limited permission firms and CCR009 for relevant ancillary credit firms. Reporting is quarterly, six-monthly or annual depending on the nature and size of the business, and firms also submit complaints returns. We prepare or review each return, reconcile it to the firm's systems and keep the reporting calendar current.
Credit firms rely on outsourced credit reference agencies, decision engines, servicing platforms, collection agencies and brokers. The firm remains responsible for outsourced activities, and SYSC 8 sets the FCA's expectations on due diligence, oversight and exit planning for important outsourcing. The full operational resilience rules in SYSC 15A apply only to some larger firms, but every firm must have business continuity arrangements proportionate to its business.
Debt management firms that hold client money must protect it under CASS 11 in the Client Assets sourcebook, and the prudential rules for debt management firms sit in CONC 10. For lenders and brokers, the threshold condition on appropriate resources in COND 2.4 requires financial resources that match the firm's risks, including the cost of redress and an orderly wind-down. We review outsourcing arrangements, client money controls and the firm's assessment of its financial resources.
Every engagement follows the same four stages, scaled to the size of the consumer credit firm and the urgency of the issue.
Assessment comes first: we review your permissions, governance, policies, management information and recent FCA correspondence against the rules that apply to you. You then receive written findings, ranked by regulatory risk, with each gap tied to the specific rule it breaches and a named owner for the fix. Remediation follows: we redraft policies and procedures, rebuild monitoring plans, correct returns and prepare board papers, and we can attend FCA meetings alongside your senior managers. Finally, ongoing support keeps the position steady after remediation, through a retained monthly review, an annual compliance monitoring programme or outsourced roles such as an outsourced compliance officer or MLRO.
Buckingham Capital Consulting (BCC) was established in 2013 and has obtained more than 250 licences in over 60 countries for payment, e-money and crypto firms. We open global markets to payment, e-money and crypto businesses: the licences to enter, the banking to operate and the compliance to scale.
For consumer credit firms, the same discipline applies: compliance that is evidenced, tested and reported to the board, so that the firm can show the FCA how its lending, collections and pricing produce fair outcomes.
Because BCC also arranges banking for regulated firms, our compliance work is written with the questions banks and safeguarding providers ask in mind. A firm whose controls satisfy the FCA and its bank at the same time spends less time answering the same questions twice. To discuss your firm, use the contact form and tell us your permissions, your current team and the issue you need resolved.
A consumer credit compliance consultant reviews lending, broking, collections and promotions against CONC, the Consumer Credit Act 1974, the Consumer Duty and SM&CR, then fixes policies, affordability controls, returns and board reporting. Many also provide ongoing monitoring or an outsourced compliance officer.
Yes. Consumer credit firms are within SM&CR as core or limited scope firms, depending on their permissions. Senior managers need FCA approval before starting, certified staff must be assessed as fit and proper annually and all staff must follow the conduct rules.
Depending on permissions, firms submit CCR001 financial data, CCR002 volumes, CCR003 lender data, CCR006 debt collection data, CCR007 for limited permission firms and CCR009 for relevant ancillary credit firms, plus complaints returns. Frequency depends on the nature and size of the business.
Lenders must show fair value on rates, fees and add-on products, support customers in financial difficulty, communicate clearly and review outcomes at board level at least annually. The FCA has focused on firms whose pricing or collections practices cause foreseeable harm.
Consumer lenders are generally within the MLRs and need a business-wide risk assessment, due diligence, monitoring and an MLRO. Many brokers and debt firms are outside the MLRs, but all FCA firms must counter financial crime risk under SYSC 6.1.1R.
Yes. BCC can provide an outsourced compliance officer for a consumer credit firm, with a monitoring programme, board reporting and support on FCA correspondence. Where the role is a senior manager function, the individual must be approved by the FCA before starting.
Tell us what you need and where you operate.