Before 1 April 2014:
consumer credit activities (including entering into consumer credit agreements) were regulated by the Office of Fair Trading (OFT)
law firms had the benefit of a group licence for consumer credit work, which was issued by the OFT to the SRA and therefore didn't need an individual licence to enter into consumer credit agreements with clients or engage in ancillary consumer credit activities
On 1 April 2014, the Financial Conduct Authority (FCA) took over regulation of consumer credit work and the SRA's group consumer credit licence disappeared, meaning law firms lost the benefit of the group licence for all consumer credit activities.
Since 1 April 2014, consumer credit activities fall within the Exempt Professional Firms (EPF) regime. You can therefore undertake certain regulated consumer credit activities under the EPF regime (ie without being authorised by the FCA), so long as:
you register on the FCA’s EPF register, and
those activities arise out of, or are complementary to, the provision of a particular professional service to a particular client
The SRA Financial Services (Scope) Rules
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