Manchester-based debt manager Money Matcher Limited is to appeal against a decision by the Financial Conduct Authority (FCA) to refuse its application for full authorisation. The Upper Tribunal will now look into the case, but until the Tribunal has had time to consider the matter, the firm’s interim permission has been revoked, and the firm is therefore not permitted to carry out regulated activities.

The FCA refused the application as it had numerous concerns over the competence of the firm’s director, who has not been named.

The firm has operated in the debt management sector since 2012.

Many of the issues stem from the departure of the firm’s former compliance officer in autumn 2014. The firm is still to appoint a successor. The director said he would carry out the role in the meantime, and he duly applied for permission to carry out the CF10 (compliance oversight) function, but the FCA is not convinced that he has the skills and experience required. The firm has indicated that it will engage an external compliance consultant, but could not provide details of the scope of the consultant’s involvement.

In the Final Notice, the FCA says that the director “admitted that he was not aware of which
Authority rules or guidelines he needed to read.” He was unable to give a satisfactory answer when asked by the FCA what risks to clients existed as a result of the firm’s business model, and conceded he had “no idea” as to what was included in the firm’s vulnerable clients procedures.

Since the compliance officer left, the firm has not carried out monitoring of the quality of advice provided by its staff, relevant management information has not been monitored and staff training has not been kept up to date. The director said that training requirements would be addressed by the compliance consultant, but could not provide details of exactly what this training would involve, or when it would be carried out.

The firm’s complaints procedure does not explain the timescale for resolving complaints, or the process by which they will be handled. Its procedure for handling client assets consists of little more than a statement of applicable FCA rules, without explaining how these will be applied within the firm, and it also fails to identify which ‘director or senior manager’ has responsibility for client assets.

In summary, the FCA believes that the firm is unable to satisfy threshold condition 2D (Appropriate resources) or condition 2E (Suitability).

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