Rebecca Kellner#5217

Rebecca Kellner

Rebecca is an associate in the Orrick, Herrington & Sutcliffe financial services regulatory team and provides advice on a broad range of financial regulation. She works with a number of regulated companies and financial institutions in different spaces, including banks, brokers, advisors, e-money institutions, payment services providers and consumer credit firms.

Typical work includes advising on issues relating to authorisation, structuring, outsourcing, systems and controls, conduct of business, financial resources, market abuse, EU directives, promotion and distribution of investments, money laundering, payment services and consumer credit.

She is particularly active in the Fintech space and provides advice for clients ranging from peer to peer lending platforms, challenger banks, app-payment providers, robo advisers as well as those working with blockchain and cryptoassets.
Contributed to


Consumer credit agreements—pre-contract requirements
Consumer credit agreements—pre-contract requirements
Practice notes

The Financial Conduct Authority (FCA) has emphasised that one of the main principles underpinning the consumer credit rules is to ensure that consumers are treated fairly. This includes ensuring a customer is provided with full pre-contract disclosure that complies with Chapter 4 of the Consumer Credit Sourcebook (CONC).This Practice Note examines pre-contract disclosure in consumer credit agreements, under the requirements of the Consumer Credit (Disclosure of Information) Regulations 2010 (SI 2010/1013) (amended by the Consumer Credit (Amendment) Regulations 2010 (SI 2010/1969) (the Disclosure Regulations) which implement the requirements of the Consumer Credit Directive (CCD) into UK law together with regulatory requirements encapsulated in Chapter 4 of the Financial Conduct Authority Sourcebook on Consumer Credit (CONC 4).

Exempt consumer credit agreements under the FSMA 2000 (Regulated Activities) Order 2001
Exempt consumer credit agreements under the FSMA 2000 (Regulated Activities) Order 2001
Practice notes

This Practice Note seeks to explain the types of agreements which will be exempt agreements under the FCA consumer credit regimes. Entering into these exempt agreements will exempt a lender from carrying out the activity of entering into a regulated credit agreement as lender. Some other regulated activities relating to consumer credit agreements may also be exempt if relating to these types of agreements. However, these are dealt with separately in other Practice Notes.

Practice Area


  • Contributing Author

Qualified Year

  • 2018


  • BPP Law School, M.A., L.P.C. with Business, 2016
  • BPP Law School, Graduate Diploma, Law, 2015
  • Rice University, B.A., History and Psychology , 2014, cum laude

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