NEWSLETTER
New For 2025
My Compliance Consultant have been working on a new Compliance Monitoring Programme web-portal which should be launched at the end of January. This will supersede the excel format version and will be accessed with your own login details. A monthly call with MCC will be an option for those firms who require assistance in populating their CMP.
The view is also to add other compliance features throughout the year such as RegData returns and Consumer Duty.
New eLearning Module: We have launched a new CPD certified eLearning module “The Credit Broker Journey.” The course objectives are that this is an entry level course for those who may be new to the role in a consumer credit brokerage firm but would be a useful reminder for all Senior managers. After completing the course, learners will know what is meant by credit brokerage. Understand your role and responsibilities. Be introduced to the types of regulated agreements. Know what rules apply to a credit broker and learn how to achieve good outcomes and avoid bad outcomes for your customers.
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Regulatory News
2024’s highlight was undoubtedly the Motor Finance sector review, The FCA conducted a review into discretionary commission arrangements in the motor finance sector highlighting the need for transparency and fair treatment of customers. FCA to consult on extending the time motor finance firms have to handle commission complaints | FCA
Buy Now Pay Later (BNPL): was hot on the heels with the HM Treasury publishing a consultation on draft legislation to regulate BNPL products. This also includes bringing certain deferred payment credit agreements.
under regulation and establish a temporary permissions regime for unauthorised firms. FCA welcomes buy now pay later consultation | FCA
Social Media Guidance: the FCA issued guidance on financial promotion on social media clarifying expectations for firms to ensure compliance with existing regulatory obligations. FG24/1: Finalised guidance on financial promotions on social media
All the above highlight the ongoing efforts to enhance consumer protection and ensure fair practices in the consumer credit market.
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Consumer Duty Arears of Focus 2024/24:
The FCA has outlined four key areas of focus:
- Embedding the Duty and raising standards.
- Enhancing understanding of the price and value outcome.
- Sector-specific priorities.
- Realising the benefits of the Consumer Duty.
The final point is largely covered by the call to input asking where the FCA can use the Duty to simplify wider requirements on retail firms, which closed in October. The FCA plans to set out its next steps here in Q2 2025. As to the remaining three, there is little new but some interesting developments of themes we have seen grow since the Duty came into force in 2023.
- On ‘Embedding the Duty’, the FCA confirms that it will publish feedback on three cross-cutting projects in Q4 2024 and Q1 2025.
- These are: the review of board/governing body reports and complaints and root cause analysis; a review of treatment of customers in vulnerable circumstances; and a review of consumer
- support outcome and supporting informed decision-making. Feedback on the first annual board reports has been eagerly awaited
since early Autumn. Given the paucity of practical guidance on the look, feel and intended depth of these reports, indications of good and poor practice here will be welcome.
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2025
Just 3 days into the new year and we have seen the first news story with 1,200 caravan owners across the country beginning legal action against holiday parks, members of the Holiday Park Action Group (HPAG) are seeking compensation for what they say are unfair increases in annual pitch fees and misleading claims about value of static caravans at the time of purchase. Although this is not currently a regulatory matter, in time it may become that due to the potential of mis-selling practises, we will watch this one very closely! ‘Ripped off’ caravan owners start compensation fight – BBC News
- Next Newsletter April 2025
Regards
Shaun