Firms wishing to carry out lending or credit broking activities need to be authorised by the FCA, both these are extremely different – most firms will be able to apply for Limited Permission as opposed to Full Authorisation. These firms will not need to supply as much information with their application and will be subject to a lower degree of supervision by the FCA.
Credit brokers may be able to apply for limited permission where this is a secondary activity, and where the main business of the firm is selling goods or providing services of a non-financial nature – like automotive dealers.
Documentation the FCA will require for all credit applicants includes:
- A regulatory business plan
- A risk management strategy
- Compliance procedures, e.g. sales process, complaints procedure, data protection procedure, rule breaches procedure
- Evidence of how the firm will ensure it will treat its customers fairly
- Evidence that the firm has systems in place to combat financial crime
- Details of the intended remuneration structure
- Marketing strategies to be used, and how clients will be sourced
- Details of the firm’s organisational structure
- Projected financial statements
- Details of any previous convictions, disciplinary action, or insolvency events
- Additional information that lenders might need to supply includes
- Details of affordability assessments the firm will carry out
Individual authorisation for key personnel, e.g. directors, chief executives, heads of compliance and anti-money laundering officers is also required. These individuals will be subject to a series of assessments regarding honesty, integrity and
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