Top ten things you need to know about the new consumer credit regime

Top ten things you need to know about the new consumer credit regime

Consumer credit is changing.

Here's Comet's at-a-glance, 'ten things you need to know', wake-up call for the new regime.

From our experience, most of those businesses affected by it have started sorting things out. However, this post is for those of you that haven’t starting doing anything yet or for those of you that would like a gentle reminder of what it is all about.

One: Time is ticking down. 111 days and counting...

Blink and its Christmas. A week later and it's 2014.

January, February and March will no doubt fly by and then, before you know it, 1 April 2014 appears on your calendar.

If you haven't started thinking about the new consumer credit regime, it isn't too late—honest!—but time is no longer on your side. You need to start the ball rolling now!

 

Two: More, not less, legislation

Unfortunately, the new regime is more complicated. New regimes are invariably more complicated. Why does it always seem to be this way?

Well, I'm afraid that I can't answer that. Such is modern life, I suppose.

The fact remains, however, that the new consumer credit regime doesn't just comprise the Consumer Credit Act 1974 and accompanying bits and bobs (as always, click on the picture for a bigger version of it) ...

 

... it now also comprises:

  • the Financial Services and Markets Act 2000 (FSMA),
  • accompanying FSMA statutory instruments, and
  • the relevant books of the FCA Handbook such as CONC (pronounced 'conk'), PRIN, SYSC ('sisk'), GEN and UNFCOG (just a collection of vowels and consonants that should never be placed together, to be fair) ...

A fair whack of new legislation to digest and get your head around!

In 111 days.

Three: Key dates

D-Day is 1 April 2014, a date that really ought to be in your diary.  

Businesses (or 'firms' in FCA-speak) without interim permission on 1 April 2014 (and which are currently authorised by the OFT) must apply for full FCA authorisation before then so that they can legally continue consumer credit activities. On this date the rules (including CONC) will come into force.

The FCA says that in principle it will not take any enforcement action b

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