ARE YOU READY FOR THE CHANGES TO FACE REGULATION?
Please find below our latest update, ahead of the Financial Conduct Authority (FCA) taking over regulation of consumer credit from the Office of Fair Trading (OFT) on 1st April 2014.
Our goal is to help you ensure your business is ready for this important regulatory change where it relates to how you do business with Premium Credit and offer our services to your customers.
We’re also introducing some other service improvements to coincide with the change in regulator, details of which are included in this briefing. We appreciate there’s a lot of information but we hope it’s clear and straightforward. If however you require any assistance or clarification please do not hesitate to contact your Business Manager. We will be in touch with further updates in the coming weeks.
YOU MUST CONFIRM 'INTERM PERMISSION' STATUS
We’re pleased to confirm that we’ve received our ‘Interim Permission’ to trade. We wanted to remind you that in order to continue trading in the provision of consumer credit after 31st March 2014, ALL firms must be registered with the FCA and have received ‘Interim Permission’ to trade. It is therefore essential that we have received a copy of your interim status by 31st March. Thank you if you’ve already provided us with that confirmation. If you haven’t yet confirmed your Interim status you MUST do this as soon as possible.
Reflecting FCA regulation in all customer facing communications
From 1st April 2014, we will have updated all customer communications by adding ‘Authorised and Regulated by the Financial Conduct Authority’. This covers credit agreements, websites, letters and marketing materials. You must destroy any paper based Premium Credit customer communications that you have in stock – they must not be used from 1st April 2014 onwards. We will issue updated communications prior to 1st April or please email us with any requests for communications to the following address: email@example.com
Rules on Financial Promotions
The FCA’s policy statement on consumer credit and its final rules was released on 28th February 2014 and we’re currently reviewing the details. This includes rules on financial promotions and communications with customers and could require changes to scripts, online content and advertising. Once we’ve finalised our review, we’ll provide a further update. Please be aware that it is your responsibility to comply with the rules insofar as they relate to your business. You must therefore review them carefully yourselves to ensure you’re compliant.
As part of our regulatory responsibilities, Premium Credit is required to take reasonable steps to ensure that our business partners are acting in accordance with the new regulations. We wish to reassure you that any monitoring will be risk based and proportionate. Where you have your own compliance resources it will obviously make sense to ensure that relevant areas, such as disclosure scripts, are included in their compliance checks. In addition, we will consider the introduction of self-certification confirming your compliance with new regulations. We will provide more details over the coming weeks.
For more information visit the FCA website
How to confirm interim permission status
Please email a copy of your ‘Interim Permission’ to us at the following dedicated email address: firstname.lastname@example.org
Alternatively a hard copy can be posted to us at the address above marked ‘Private & Confidential’ for the attention of Scott Delonnette.