The FCA recently sent out a notice to direct firms regarding amendments to the threshold conditions for limited permission authorisation of credit brokers.

These amendments seem to have caused a bit of a “stir” in the industry as they are being interpreted in many different ways, so here’s our view on things, as always we would suggest you seek independent professional advice before you make any decisions yourself.

The amendment notice stated:

“From 24 March 2015 the scope of the limited permission regime was extended to cover all broking of consumer hire and hire-purchase agreements.”
However it also states:

“Firms will, however, be eligible for limited permission only if they do not engage in any regulated activity requiring full permission”

Debt counselling and debt adjustment are activities that require full permission unless you undertake them as a supplier or you are a “not for profit” body that is involved in the broking activity.

On this basis the notice suggests that you can take advantage of falling within the Limited Permissions authorisation process if you offer Hire Purchase or Lease in relation to any goods or services, as long as you would not get involved in any form of refinance or dealing with trade-ins / part exchanges (where there is outstanding finance).

Alternatively you could become an Appointed Representative of AFS Compliance and let us take responsibility !

Contacts
AFS Group, Asset Finance Solutions & AFS Compliance
  • Greenbank Court, Challenge Way, Greenbank Business Park, Blackburn, BB1 5QB
  • Tel: 01254 958777
Synergy Commercial Finance
  • Lindum Business Park, York Road, Elvington, York YO41 4XR
  • Tel: 01904 481786