FCA’s Interim Permission Update

FCA updates its web information about interim permission

At such an important time for credit firms, it is vital that those practising in this area check the website of the Financial Conduct Authority (FCA) on a regular basis.

The interim permission page, as of the November 5 update, highlighted a number of important issues.

Firms new to consumer credit, or existing FCA-authorised firms wishing to add credit to their permitted activities, can submit credit authorisation applications now. However, existing holders of interim permission can only apply to upgrade to full permission or limited permission during a defined three month period. When this three month period commences depends on the type of business the firm carries out, and in some cases, on their postcode as well. For some firms, the application period has already commenced, and the process will be complete for all firms by March 31 2016.

Interim permission was automatically granted to all former holders of Consumer Credit Licences who wished to continue trading and who met certain conditions. But now these firms must complete the comprehensive FCA authorisation process, which involves supplying a great deal of information about the firm and its intended activities.
Regardless of when a firm’s application period is though, it must keep the FCA informed of any significant changes which occur during the interim permission period. The Consumer Credit Interim (CCI) System, accessible via the FCA website, can be used to update basic details such as address or telephone number.

It is also important that the FCA knows who a firm’s nominated ‘contact’ at an interim permission firm is. If the designated contact wishes to pass this role on to a colleague, they must log in to the system and make the necessary changes. If the named contact has left the firm, then the firm should contact the FCA immediately for advice on how to proceed.

This CCI system can also be used if a firm wishes to reduce the number of activities for which it holds interim permission. However, if a firm wants to add additional areas to its list of permitted credit activities, then it must submit an authorisation application.

Firms are also reminded that if they hold interim permission they cannot have any appointed representatives (ARs) – other firms or persons who are not FCA-authorised, but who are subject to supervision by an authorised firm for regulatory purposes.

If a holder of interim permission becomes an AR in the longer term, then they can cancel their interim permission via the CCI system.

Holders of interim permission who do not wish to upgrade their authorisation are asked to inform the FCA of their intentions. Not only should they cancel this permission via the CCI system before ceasing to trade, they should also inform the FCA via email to application.period@fca.org.uk. Firms to whom this applies will need to ensure that they cease trading immediately once their permission lapses.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.