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So what is the big deal about 1 October?
85 days until Christmas?
But for most commercial lawyers and businesspeople, it is the date when a flurry of new laws come into force.
Here’s the ones that they should be looking out for this year in particular:
Fraud, bribery and money laundering offences sentencing guideline:
The Sentencing Council published the definitive guideline on fraud, bribery and money laundering offences on 23 May. This guideline comes into effect on 1 October and applies to all offenders aged 18 and older and to organisations who are sentenced on or after 1 October.
Consumer credit: Financial Conduct Authority (FCA) starts to consider applications for full authorisation:
The FCA will start considering applications for full authorisation from those firms with interim permission. The FCA states that the authorisation application periods will last for three months and run from 1 October to 31 March 2016. The FCA is inviting firms in the credit markets causing most consumer harm (such as high-cost short term credit lenders, logbook lenders and debt management firms) to apply for authorisation before any other firms. A summary of the requirements that come into effect when a firm obtains authorisation is set out in Table 1.4 of FCA Policy Statement PS14/3 (at page 14).
Consumer credit: reporting regime starts:
For those firms which are fully authorised the six-monthly or annual reporting regime starts (although not for those firms who only have interim permission).
Consumer credit: transitional period for rules in CONC ends:
For all firms generally the transitional period for the conduct rules set out in the Consumer Credit sourcebook of the FCA Handbook of Rules and Guidance (CONC) ends.
Consumer credit: new rules for peer-to-peer lenders:
New rules come into force for peer-to-peer lenders (such as requirements on adequate explanations and creditworthiness)
Consumer credit: not-for-profit debt advice bodies with limited permission: transitional period ends:
For grandfathered not-for-profit debt advice bodies the transitional period for detailed client money rules ends
Consumer credit: High-cost short-term credit and home-collected credit:
Once authorised, product sales data (PSD) reporting requirements
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