ADVICE NOTE FIRST EDITION (NOVEMBER 2013)
|
|
- Eric Howard
- 5 years ago
- Views:
Transcription
1 Consumer Credit Act 1974 Implications for Golf Clubs across Scotland Disclaimer: The Scottish Golf Union (SGU) and Scottish Ladies' Golfing Association (SLGA) have sought advice from law firm DLA Piper on the implications for golf clubs across Scotland of the Consumer Credit Act This guidance note sets out a summary of that advice. Please note that the advice provided in this guidance is general in nature and Clubs may wish to take additional legal advice, tailored to their own particular circumstances. Q1. When does a golf club need a consumer credit licence? A. A consumer credit licence is required, amongst other things, to carry on a consumer credit business or an ancillary credit business. In the context of golf clubs, the most likely businesses the golf club could be engaged in is one of the following. The consumer credit business of providing credit. A consumer credit business is any business being carried on by a person so far as it comprises or relates to the provision of credit by him, or otherwise his being a creditor, under regulated consumer credit agreements. A category "A" consumer credit licence is needed for this activity. The ancillary credit business of credit brokerage. Credit brokerage is the effecting of introductions of individuals desiring to obtain credit to persons carrying on a consumer credit business. Although the law in this area is not perfectly clear it is probable that an introduction will be effected if a club undertakes some activity which is more than just giving the member the creditor's contact details and which positively facilitates the member's communication with the creditor for the purposes of obtaining credit. The passive display of an advert in a club will not constitute credit brokerage but examples of what is credit brokerage could include: o calling the creditor and passing on the member's details so that the creditor can offer credit; o presenting an application form to a member while at the club; and o including a credit application form as part of a membership renewal pack so that a member can complete this and send it on to the creditor. A category "C" consumer credit licence is needed for this activity. JV/LIVDP/UKM/
2 We understand that some golf clubs have arrangements with Fairway Credit, whereby golf clubs introduce their members so that Fairway Credit can provide credit for membership fees and this is an example of credit brokerage. There are other types of ancillary credit business for which one or more different categories of licence may be required, although these are unlikely to apply to golf clubs. This note deals only with categories "A" and "C". Q2. Is there any dispensation from the licencing provisions which could apply to golf clubs? A. The CCA does not require that credit should be provided by a person who carries on the business of money lending or of providing credit, or indeed any business at all, in order for a licence to be required. It follows that there is no dispensation for golf clubs. Q3. How do we know when we are providing credit? A. This question is important because it is only when either credit is being provided, or when introductions are made to a person that will provide credit, that a licence may be required. Credit is defined in the Consumer Credit Act 1974 ("CCA") to include a cash loan or any other form of financial accommodation. The meaning of a cash loan is clear enough, but the meaning of financial accommodation may be best understood through the use of some examples. A golf club which sells an annual membership costing, say, 1,000 repayable by 10 monthly instalments of 100 would be providing a financial accommodation and, therefore, providing credit. Had there not been an agreement to defer payment, payment for the membership would have been earned by the golf club at the point the membership was provided. As, in this example, payment is deferred credit is being provided. A golf club which sells a monthly membership on terms that the member pays a set sum per month which covers that month's membership (that is, on a pay-as-you go basis) is not providing credit. The member would be paying for the service provided to him as that service is being provided. Even if the terms of the membership agreement tie the member to a minimum membership period, that would still not affect the analysis that no credit is being provided. JV/LIVDP/UKM/
3 Such arrangements would be wholly outside the scope of the CCA because no financial accommodation would be being given and so no licence would be needed. It is also generally agreed that the time in the month when payment is made for the month's membership would not affect this analysis. If a member were to pay in full for their first year's membership and then pay in advance for the following year's membership, this would not represent the provision of credit, because there would be no financial accommodation. The member would be paying in advance for a service which would then be provided during the course of the following year. Paying on a monthly pay-as-you-go basis in the following year would also not represent the provision of credit, for the same reason as in year one. The general principle is that a debt is deferred, and credit extended, whenever the contract provides for the debtor to pay, or gives him the option to pay, later than the time at which payment would otherwise have been earned under the express or implied terms of the contract. Q4. If no interest is charged for credit provided, does that make any difference? A. Whether a creditor charged interest or not does not affect the analysis of whether credit is being provided. Q5. Does any exemption apply? A. A consumer credit licence is only required when the creditor is providing credit under agreements which are regulated by the CCA. There are a small number of exemptions which can apply to certain types of agreement, one of which in particular may apply to golf clubs. In order for the exemption to apply, certain criteria must be satisfied. In particular, the agreement must be one for the provision of fixed-sum credit (which will almost certainly be the case) under which: the total number of payments to be made by the debtor must not exceed four; those payments are required to be made within a period not exceeding 12 months beginning with the date of the agreement; and the credit must be provided without interest and without any other charges. If a club wishes to avoid the need to be licensed, it may be possible to structure the way in which they offer credit so as to fall within this exemption. JV/LIVDP/UKM/
4 Q6. Can the SGU & SLGA obtain a group licence on behalf of affiliated clubs? A. Group licences are available to bodies such as the National Association of Citizen's Advice Bureaux and the Institute of Chartered Accountants in England and Wales. We would not expect a group licence to be available to the SGU/SLGA. Q7. If we are providing credit, and should have a consumer credit licence, what else do we have to deal with? A. The CCA is a wide ranging piece of legislation which imposes a great many obligations on a creditor, beyond merely holding a licence. Examples of legislation which would apply if credit under regulated agreement is provided include the following. There are rules about the way in which credit facilities should be advertised. There are rules which must be followed prior to the entry into of an agreement such as assessing the creditworthiness of the member and that they can afford to make the repayments. There are very detailed regulations regarding the form and contents of agreements which are regulated by the CCA. There are rules which must be followed during the lifetime of the agreement, and when it is terminated due to the debtor's breach. There is no discretion within the CCA which allows a smaller lender, such as a golf club, to only comply with part of the law. If credit is being provided, then the whole of the CCA applies, as it would to any other lender, such as a bank. All of the rules are very prescriptive and even very minor deviations from them can have an adverse effect on the ability to enforce the credit agreement. By contrast, if a golf club acts as a credit broker, the duties arising under the CCA are relatively limited, reflecting the limited nature of the activity the golf club is engaged in. The key requirements will relate to the need to be licensed, and there are some rules with respect to the way in credit adverts are prepared. Q8. What are the sanctions if we get this wrong? A. Under the current law there are a number of key consequences from failing to comply with CCA legislation. Carrying on a consumer credit business while unlicensed is both a civil and a criminal offence. JV/LIVDP/UKM/
5 Failing to comply with many of the rules set out in the CCA such as with respect to the form and contents of regulated agreements can render the agreement "not properly executed". If a golf club wanted to enforce such an agreement it would be necessary to obtain a court order to do so. This could result in a member not paying his fees while continuing to use the golf club's facilities. Q9. How can a licence be obtained and what does it cost? A. Currently, licences are obtained from the Office of Fair Trading ("OFT"). Applications can be made online through the OFT's website and applying is a relatively straight forward, form-filling, exercise. The OFT website currently states that the fee for a partnership, company or other organisation is 1,466. The cost of a licence is the same whether the applicant is applying for a category "A" or "C". If a golf club is providing credit directly, and so needs a category "A" licence, then the OFT will undertake a more rigorous assessment to confirm that that golf club is fit to hold their licence. The position with respect to licensing is made a little more complex at present because of the plan for the regulation of consumer credit to be transferred to the Financial Conduct Authority ("FCA") with effect from 1 April Any golf club which currently has a licence, or a golf club which obtains one in the near future, will need to apply to the FCA for "interim permission". Obtaining interim permission will allow the licence holder to carry on engaging in the licensable activities allowed for by his licence after 1 April In due course, licence holders will be invited by the FCA to apply for full permission to carry on what will then be FCA authorised activities. It does not appear to be possible to make one application for a new consumer credit licence, and for interim permission, at the same time. The fee to apply for interim permission is 350. The fees for full authorisation to enter into consumer credit agreements will range from 1,000 for straightforward applications, to 15,000 for more complex ones. Some activities will be regarded by the FCA as being "lower risk" so firms engaged in those activities will be subject to less scrutiny and will be referred to as having "limited permission". A golf club introducing its members to a creditor as a secondary activity would probably only require limited permission. The fees to apply for limited permission are expected to be JV/LIVDP/UKM/
6 There will also be annual/periodic fees payable to the FCA based on the consumer credit income earned by the firm. The fee structure is currently subject to consultation so it is not possible to provide more certain information but further information will be made available on the FCA's website in due course. Q10. How will the changes to the law affect golf clubs? A. Golf clubs carrying on either a consumer credit business or an ancillary credit business will see considerable changes in the way they are regulated, once the FCA takes over regulation of this sector. The activities for which a consumer credit licence has historically been required will not change significantly although the new definition of credit broking will be somewhat wider than the former definition of credit brokerage so that more types of activity are likely to lead to the need to be authorised by the FCA. While being proportionate to the type of activity a firm wished to engage in, the FCA's authorisation process will be far more rigorous that the process currently in place to obtain a consumer credit licence. For example, firms seeking authorisation will have to satisfy certain "threshold conditions" which will confirm that they are adequately supervised and have the appropriate resources to be authorised. Historically the OFT has not tended to intervene in markets to a great extent. If the OFT has been aware of non-compliant activities it has only tended to intervene when there is a significant level of consumer detriment. The FCA has already indicated that it will be a more interventionist regulator, taking more action more quickly when necessary. Rather than being focussed on compliance with specific law and regulations, the FCA will work to ensure that the outcome customers experience when taking credit are good. Where the FCA finds that customers are experiencing poor outcomes it will have a wider range of powers available. The FCA's enforcement toolkit includes the ability to vary or remove a firms' permissions, sometimes with immediate effect, to impose unlimited fines and to require firms to provide customers with redress and restitution. A member of a golf club can sue his/her own golf club, and there is precedent for members taking their own golf clubs to court in Scotland. January 2014 DLA Piper UK LLP JV/LIVDP/UKM/
Consumer credit authorisation Guidance for housing associations
Consumer credit authorisation Guidance for housing associations www.housing.org.uk Contents Introduction 3 When is authorisation required? 4 Activities requiring authorisation 6 Summary of regulated activities
More informationFinancial Regulation: An overview of the FCA s proposal of the new Consumer Credit regime October 2013
Financial Regulation: An overview of the FCA s proposal of the new Consumer Credit regime October 2013 Consultation Paper 13/10: Detailed Proposals for the FCA regime for Consumer Credit In early October
More informationCitizens Advice Scotland Scottish Association of Citizens Advice Bureaux
Citizens Advice Scotland Scottish Association of Citizens Advice Bureaux www.cas.org.uk Financial Conduct Authority Detailed proposals for the FCA regime for consumer credit Response from Citizens Advice
More informationConsumer credit regulation: detailed proposals on the new FCA regime and implications for members
Updated: November 2013 Consumer credit regulation: detailed proposals on the new FCA regime and implications for members Summary Consumer credit regulation will move on 1 April 2014 from the Office of
More informationContact details.
HM Treasury & Department for Business, Innovation & Skills A new approach to financial regulation: transferring consumer credit regulation to the Financial Conduct Response from the Association of British
More informationDetails of FCA Consumer Credit Regime (13/29) 14 October 2013
CPA Audit LLP, Talbot House, 8-9 Talbot Court, London EC3V 0BP Telephone: 020 7621 9010 Facsimile: 020 7621 9011 email: info@cpaaudit.co.uk web: www.cpaaudit.co.uk Details of FCA Consumer Credit Regime
More informationLET ME TAKE YOU BY THE HAND...
LET ME TAKE YOU BY THE HAND... FCA Consumer Credit Limited Permission Application Guidance for Non Sole Trader Practices Click here to get started! medenta putting finance into practice Contents... Page
More informationFINANCIAL GUIDANCE AND CLAIMS BILL: BACKGROUND APPENDIX FOR BILL COMMITTEE ON CONSIDERATION OF AMENDMENT NC12.
FINANCIAL GUIDANCE AND CLAIMS BILL: BACKGROUND APPENDIX FOR BILL COMMITTEE ON CONSIDERATION OF AMENDMENT NC12. 1. INTRODUCTION 1.1 LawWorks (the Solicitors Pro Bono Group) is a charity that brokers free
More informationTransfer of consumer credit to the Financial Conduct Authority. Sam Stoakes
Transfer of consumer credit to the Financial Conduct Authority. Sam Stoakes 1 1 April 2014 Financial Conduct Authority takes over consumer credit regulation from the Office of Fair Trading This creates
More informationVariation of Permission (VOP) Application
Variation of Permission (VOP) Application Consumer Credit Activities Firm Name The name displayed on the FCA register at present Firm Reference Number Your 6 digit FRN number Does the firm have an Interim
More informationFG18/6: Helping tenants find alternatives to high-cost credit and what this means for social housing landlords
Finalised guidance FG18/6: Helping tenants find alternatives to high-cost credit and what this means for social housing landlords December 2018 1 Introduction 1.1 This document aims to assist social housing
More informationFCA CP 13/10 Detailed proposals for the FCA regime for consumer credit. Response from the Association of British Credit Unions Limited (ABCUL)
FCA regime for consumer credit Response from the Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications Manager abbie.shelton@abcul.org Or Matt Bland
More informationConsultation Response. High-level proposals for an FCA regime for consumer credit. Response from the Money Advice Service 1 May 2013.
Consultation Response High-level proposals for an FCA regime for consumer credit Response from the Money Advice Service 1 May 2013 Colin Kinloch Debt Advice Policy Manager Colin.Kinloch@moneyadviceservice.org.uk
More informationFrance Germany Italy Netherlands Spain Portugal UK. Yes Yes Yes Yes Yes Yes Yes
1. Cross-border activities that trigger Physical presence of employees (albeit not on a permanent basis) Soliciting potential clients Actually conducting financial services (e.g. signing contracts, accepting
More informationFCA Consultation CP 13/10 December 2013 The ABI s response to proposals for the FCA regime for consumer credit
FCA Consultation CP 13/10 December 2013 The ABI s response to proposals for the FCA regime for consumer credit The ABI is the voice of insurance, representing the general insurance, protection, investment
More informationSCOTTISH GOLF UNION & SCOTTISH LADIES GOLFING ASSOCIATION GOLF CLUB STRUCTURES FREQUENTLY ASKED QUEST IONS
SCOTTISH GOLF UNION & SCOTTISH LADIES GOLFING ASSOCIATION GOLF CLUB STRUCTURES FREQUENTLY ASKED QUEST IONS This guidance has been prepared for the Scottish Golf Union and Scottish Ladies' Golf Union by
More informationSRA BOARD 21 January 2015
Regulation of Consumer Credit Activities Purpose 1 The purpose of this paper is: i) to provide the Board with an update on discussions with the Financial Conduct Authority (FCA) and the Treasury (HMT)
More informationConsultation response
Consultation response SRA: Regulation of consumer credit activities Overview 1. Regulation of consumer credit activities is specialised and complex. Credit activities (and in particular debt collection)
More informationFINANCIAL SERVICES (BANKING REFORM) BILL
FINANCIAL SERVICES (BANKING REFORM) BILL EXPLANATORY NOTES INTRODUCTION 1. These Explanatory Notes relate to the Financial Services (Banking Reform) Bill as introduced in the House of Commons on 4 February
More informationMoney Advice Trust response to the Financial Conduct Authority consultation on High-level proposals for an FCA regime for consumer credit
Money Advice Trust response to the Financial Conduct Authority consultation on High-level proposals for an FCA regime for consumer credit 1 About the Money Advice Trust The Money Advice Trust (MAT) is
More informationConsumer Credit sourcebook. Chapter 5. Responsible lending
Consumer Credit sourcebook Chapter esponsible lending CONC : esponsible lending Section.1 : Application.1 Application.1.1 This chapter applies to a firm with respect to consumer credit lending, unless
More informationJargon Buster. Everything you need to know made clear
Jargon Buster Everything you need to know made clear This Jargon Buster is designed to make everything easy to understand and explain our terms from A Z. Keep it safe inside your folder as your go-to-guide
More informationBriefing Sheet Consumer Credit & Debt Advice
Briefing Sheet Consumer Credit & Debt Advice In this briefing note we provide an update on changes to the regulation of consumer credit and debt advice at pro bono clinics January 2015. Overview On the
More informationThe FCA Consumer Credit Regime
The FCA Consumer Credit Regime The FCA Consumer Credit Regime Introduction Responsibility for the consumer credit regime was transferred to the FCA from the OFT on 1 April 2014 and the licensing regime
More informationCOMPANY INSOLVENCY. Procedures open to an insolvent company are as follows: Administration. Company Voluntary Arrangement (CVA)
COMPANY INSOLVENCY A company becomes insolvent if it has insufficient assets to meet its liabilities and/or it cannot pay its debts on the due dates. It is the directors responsibility to know whether
More informationADMINISTRATIVE SUPPORT TO THE JUDICIARY IN THE UK INSOLVENCY SYSTEM
INSOLVENCY REFORM IN ASIA: AN ASSESSMENT OF THE RECENT DEVELOPMENTS AND THE ROLE OF JUDICIARY Bali - Indonesia, 7-8 February 2001 ADMINISTRATIVE SUPPORT TO THE JUDICIARY IN THE UK INSOLVENCY SYSTEM Prepared
More informationSee article 36A4 of The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, S.I. 2001/544. 2
SERVICE-SPECIFIC GUIDANCE NOTE Consumer Credit Who should read this? As at October 2014, the Phone-paid Services Authority notes that the primary providers of consumer credit services in the premium rate
More informationUnited Kingdom Glossary of Insolvency Terms. Authors: David WHITE & John FRANCIS, Association of Business Recovery Professionals (R3)
United Kingdom Glossary of Insolvency Terms Authors: David WHITE & John FRANCIS, Association of Business Recovery Professionals (R3) Updated: July 2007 Note: The definitions and explanations are not intended
More informationCredit card market study: Consultation on persistent debt and earlier intervention remedies
Credit card market study: Consultation on persistent debt and earlier intervention remedies StepChange Debt Charity consultation response to the Financial Conduct Authority July 2017 StepChange Debt Charity
More informationProviding intelligent legal solutions T F
What is the CRC? The CRC Energy Efficiency Scheme (CRC) is a new UK-wide mandatory emissions trading scheme, which applies to large businesses and public sector organisations. It came into operation on
More informationTobacco Illicit Trade Protocol licensing of equipment and the supply chain HMRC. Chartered Trading Standards Institute response
Tobacco Illicit Trade Protocol licensing of equipment and the supply chain HMRC Chartered Trading Standards Institute response May 2016 www.tradingstandards.uk reg.no. RC000879 About The Chartered Trading
More informationThe Perimeter Guidance manual. Chapter 4. Guidance on regulated activities connected with mortgages
The Perimeter uidance manual Chapter uidance on regulated PER : uidance on regulated Section.1 : Application and purpose.1 Application and purpose.1.1 Application This chapter applies to any person who
More informationRescue Recovery Renewal Is a Voluntary Arrangement Right For Me?
Rescue Recovery Renewal Is a Voluntary Arrangement Right For Me? Association of Business Recovery Professionals IS A VOLUNTARY ARRANGEMENT RIGHT FOR ME? Introduction 1. Since April 2002, the regulators
More informationAssociation of Mortgage Intermediaries response to HM Treasury s consultation on the Implementation of the EU mortgage credit directive (MCD)
Association of Mortgage Intermediaries response to HM Treasury s consultation on the Implementation of the EU mortgage credit directive (MCD) This response is submitted on behalf of the Association of
More informationCAYMAN ISLANDS. Supplement No. 21 published with Extraordinary Gazette No. 53 of 17th July, MUTUAL FUNDS LAW.
CAYMAN ISLANDS Supplement No. 21 published with Extraordinary Gazette No. 53 of 17th July, 2015. MUTUAL FUNDS LAW (2015 Revision) Law 13 of 1993 consolidated with Laws 18 of 1993, 16 of 1996 (part), 9
More informationMoneylending Review of the Consumer Protection Code for Licensed Moneylenders. Consultation Paper CP 118
Moneylending Review of the Consumer Protection Code for Licensed Moneylenders Consultation Paper CP 118 March 2018 [Type here] Review of the Consumer Protection Code for Licensed Moneylenders 1 Contents
More informationThe Perimeter Guidance Manual. Chapter 15. Guidance on the scope of the Payment Services Regulations 2017
The Perimeter Guidance Manual Chapter Guidance on the scope of the Payment Services PERG : Guidance on the Section.1 : Introduction.1 Introduction The purpose of this chapter is to help businesses in the
More informationFINAL NOTICE Accordingly, the Authority has today made a Prohibition Order in respect of Mr Whitehurst.
FINAL NOTICE To: Address: Adrian Lee Whitehurst 2 Alma Road, Stockport, Cheshire SK4 4PU Date: 23 October 2017 1. ACTION 1.1. For the reasons given in this Notice and pursuant to section 56 of the Act,
More informationSECURITIES (LICENSING) RULES 2007
The text below is an internet version of the rules issued by the Commission under the Securities Act 2005 and is for information purpose only. Whilst reasonable care has been taken to ensure its accuracy,
More informationPersonal Glossary of Terms
Annual Report Insolvency practitioners are obliged to produce regular reports detailing their actions, including an account of what money they have received from insolvent companies and individuals and
More informationFINAL NOTICE. 4. For the reasons listed below, the Authority has refused the Application.
FINAL NOTICE Super Fast Loan Limited 18A Castle Street Kingston Upon Thames Surrey KT1 1SS 19 January 2015 ACTION 1. By way of an application dated 14 October 2013, Super Fast Loan Limited applied to the
More informationRESPONSE OF THE SOLICITOR SOLE PRACTITIONERS GROUP TO THE SRA CONSULTATION REGULATION OF CONSUMER CREDIT THE SRA S REGULATORY ARRANGEMENTS
RESPONSE OF THE SOLICITOR SOLE PRACTITIONERS GROUP TO THE SRA CONSULTATION REGULATION OF CONSUMER CREDIT THE SRA S REGULATORY ARRANGEMENTS Question 1: Do you agree that it is appropriate for the consumer
More informationA New Regulatory Framework for Credit Servicing Firms in Ireland
September 2015 A New Regulatory Framework for Credit Servicing Firms in Ireland Background For further information on any of the issues discussed in this article please contact: The Consumer Protection
More informationBRITISH VIRGIN ISLANDS BANKS AND TRUST COMPANIES ACT, (as amended, 2001) ARRANGEMENT OF SECTIONS. PART I - Preliminary. PART II - Licences
BRITISH VIRGIN ISLANDS BANKS AND TRUST COMPANIES ACT, 1990 1 (as amended, 2001) ARRANGEMENT OF SECTIONS 1. Short title PART I - Preliminary 2. Interpretation. PART II - Licences 3. Requirement for licence.
More informationGuidance for the Designated Professional Body Rules
Regulation Guidance for the Designated Professional Body Rules 2018 rics.org/regulation Guidance for the Designated Professional Body Rules i Effective from October 2018 rics.org/regulation Contents 1
More informationDOCUMENT
Tel 01886 812943 Fax 01886 812935 Email info@ngcaa.co.uk Website www.ngcaa.co.uk DOCUMENT Title: CASC Setting up a Trading Subsidiary Revision: 1 The NGCAA has put together a package for clubs to assist
More informationPENSION SCHEMES BILL EXPLANATORY NOTES
PENSION SCHEMES BILL EXPLANATORY NOTES INTRODUCTION 1. These explanatory notes relate to the Pension Schemes Bill as brought from the House of Commons on 26th November 2014. They have been prepared by
More informationUnit F. Payment methods v1.2. Copyright 2015 Citizens Advice. All rights reserved.
Unit F Payment methods v1.2 Citizens Advice is an operating name of the National Association of Citizens Advice Bureaux. Registered charity number 279057 VAT number 726 0202 76 Company limited by guarantee
More informationGuidance for candidates and agents
Local elections in England May 2019 Guidance for candidates and agents Part 3 of 6 Spending and donations This guidance is for the local elections in England being held on 2 May 2019. Translations and
More informationREGULATORY INFORM. The Newsletter from CCTA April 2011
REGULATORY INFORM The Newsletter from CCTA April 2011 THE CONSUMER CREDIT TRADE ASSOCIATION REGULATORY INFORM 1 Welcome to Regulatory Inform Over the last three months, Graham Haxton-Bernard our legal
More informationNational Consumer Credit Protection Bill 2009 and National Consumer Credit Protection (Transitional and Consequential Provisions) Bill 2009
National Consumer Credit Protection Bill 2009 and National Consumer Credit Protection (Transitional and Consequential Provisions) Bill 2009 Exposure Draft Submission to the Treasury May 2009 INTRODUCTION
More informationShort Term Lending Customer information
Short Term Lending Customer information About your mortgage 0800 116 4385 precisemortgages-customers.co.uk Introduction We have provided this Customer Information Booklet with your Mortgage Offer to help
More informationICAEW is pleased to respond to your request for comments on Debt management (and credit repair services) guidance.
15 September 2011 Our ref: ICAEW Rep 84/11 Aaron Berry Office of Fair Trading Fleetbank House 2-6 Salisbury Square London EC4Y 8JX By email: dmguidance-consult@oft.gsi.gov.uk Dear Aaron Debt management
More informationV0215 Copyright Comply
An Introduction to Financial Conduct Authority (FCA) Regulation V0215 FCA Regulation Module Objectives Welcome to the training module for an introduction to the Financial Conduct Authority Regulation for
More informationGAS SAFE REGISTER. Brand Enforcement Policy. November 2017 P001_BEP001 V5.0
GAS SAFE REGISTER Brand Enforcement Policy November 2017 P001_BEP001 V5.0 Contents 1. Scope... 3 2. Background... 4 3. Brand use... 4 3.1 Registered businesses... 4 3.2 Legacy businesses... 5 3.3 New applicant
More informationFinancial Conduct Authority Pension Wise recommendation policy
Financial Conduct Authority Pension Wise recommendation policy July 2015 Policy Statement PS15/17 Pension Wise recommendation policy PS15/17 Contents Abbreviations used in this paper 3 1 Overview 5 2
More informationAppendix 3 Handling Payment Protection Insurance complaints
Appendix Handling Payment Protection Insurance.1 Introduction App.1.1 Application (1) This appendix sets out how: (a) a firm should handle relating to the sale of a payment protection contract by the firm
More informationACCA F4 (ENG) Corporate and Business Law. December Final Assessment Answers
ACCA F4 (ENG) Corporate and Business Law December 04 Final Assessment Answers To gain maximum benefit, do not refer to these answers until you have completed the final assessment questions and submitted
More informationTHE BANKING ACT 1) of August 29, A unified text CHAPTER 1 GENERAL PROVISIONS
THE BANKING ACT 1) of August 29, 1997 A unified text drawn up on the basis of Journal of Laws (Dziennik Ustaw Dz.U.) 2002 No. 72, item 665; No. 126, item 1070; No. 141, item 1178; No. 144, item 1208; No.
More informationFor example, purchasing a BTL, building a property to sell or working capital.
APPLICATION FORM Please complete this loan application in as much detail as possible as it will enable us to process your loan quickly. Once complete, please email a copy to enquiries@affirmative.co.uk
More informationResponse to SRA Consultation on regulation of consumer credit activities
Response to SRA Consultation on regulation of consumer credit activities 15 December 2014 2014 The Law Society. All rights reserved. The Law Society s response to the SRA s consultation on regulation of
More informationGuidance on consumer credit debt counselling
Guidance on consumer credit debt counselling The following guidance explains when firms providing advice to a client will be performing the consumer credit regulated activity of debt counselling. The guidance
More informationBridging Loans Additional guarantor form
Bridging Loans Additional guarantor form Intermediary details Contact name Email Your customer reference Fax number (including STD code) Are you? Directly Authorised by the FCA Part of a Network Financial
More informationGuidance for candidates and agents
Local elections in Wales 2017-18 Guidance for candidates and agents Part 3 of 6 Spending and donations This guidance is for the local elections in Wales in 2017 and 2018. Translations and other formats
More informationDraft Deregulation Bill Written evidence from R3, the insolvency trade body
Draft Deregulation Bill Written evidence from R3, the insolvency trade body Introduction 1. R3 represents 97% of UK Insolvency Practitioners (IPs) - the only professionals authorised to take insolvency
More informationCONSUMER CREDIT (CREDIT BROKING) INSTRUMENT 2014
CONSUMER CREDIT (CREDIT BROKING) INSTRUMENT 2014 Powers exercised A. The Financial Conduct Authority makes this instrument in the exercise of the following powers and related provisions in the Financial
More informationStandard Terms of Business
The following Standard Terms of Business apply to all engagements accepted by BPU Chartered Accountants. All work carried out is subject to these terms except where changes are expressly agreed in writing.
More informationFINAL NOTICE. Neil Moir. Anglesey. 19 August 2015 ACTION
FINAL NOTICE Neil Moir Anglesey 19 August 2015 ACTION 1. By an application dated 1 April 2014 ( the Application ) Mr Neil Moir, trading as Readymoney, ( Mr Moir ) applied under section 40 of the Financial
More informationGuide to Section 75 CreditCards.com
Guide to Section 75 1 Guide to Section 75 One of the main benefits cited for people using credit cards is the additional protection afforded to credit card transactions under Section 75, but what is it?
More informationStepChange Debt Charity consultation response to HM Treasury
Goods Mortgages Bill: Consultation StepChange Debt Charity consultation response to HM Treasury October 2017 StepChange Debt Charity London Office 6th Floor, Lynton House, 7-12 Tavistock Square, London
More informationUNINCORPORATED ASSOCIATIONS: CONVERSION TO A SCIO
UNINCORPORATED ASSOCIATIONS: CONVERSION TO A SCIO CONFIDENCE THROUGH CLARITY A Brief Guide K:\COPYDOCS\CI675\X293\14251678.DOC 1 Important Notice You should be aware that there are significant legal and
More informationFINAL NOTICE Accordingly, the Authority has today made a Prohibition Order in respect of Mrs Whitehurst.
FINAL NOTICE To: Address: Christine Whitehurst 2 Alma Road, Stockport, Cheshire SK4 4PU Date: 23 October 2017 1. ACTION 1.1. For the reasons given in this Notice and pursuant to section 56 of the Act,
More informationADDITIONAL BORROWING/ PURCHASE OF EQUITY FORM STAGE 2 OF 2
ADDITIONAL BORROWING/ PURCHASE OF EQUITY FORM STAGE 2 OF 2 Customer Type e.g. Buy to Let, Self Build, Mainstream Existing Account Number(s) Please submit Stage 1 of the Additional Borrowing Form to receive
More informationUnderstanding Your Limited Permission Consumer Credit Authorisation Application. The Plain English Guide
Understanding Your Limited Permission Consumer Credit Authorisation Application The Plain English Guide Contents 2 Welcome 6 Why am I reading this Guide? 6 Why is this Guide so long? 6 How long will it
More informationinsolvency insolvency newsletter issue 16 December 2008
insolvency 16 insolvency newsletter issue 16 December 2008 Contents 1. Technical News 3 2. Regulatory News 5 3. Legislation 6 4. Cases 7 Editor: John Davies, Head of Business Law e-mail: daviesj@accaglobal.com
More informationMortgages Regulated Mortgage Contracts and the FCA
Mortgages Regulated Mortgage Contracts and the FCA NLD - Compliance Manual - Mortgages - March 2014 1 Chapter 1 Regulated Mortgage Contracts and the FCA 1.1 When does MCOB apply? 1.2 What is a regulated
More informationBUYERS GUIDE TO PROFESSIONAL INDEMNITY INSURANCE
1. GUIDANCE BUYERS GUIDE TO PROFESSIONAL INDEMNITY INSURANCE 1.1 This guidance is to help you to make an informed choice when purchasing professional indemnity insurance and to use the market effectively.
More informationQ&A for LGPS Members Freedom and Choice - Transfers from the LGPS to Defined Contribution Schemes
Q&A for LGPS Members Freedom and Choice - Transfers from the LGPS to Defined Contribution Schemes From 6 April 2015, the Government introduced greater flexibility ( Freedom and Choice ) in the way individuals,
More informationMONGOLIA LAW ON NON BANK FINANCIAL ACTIVITIES
MONGOLIA LAW ON NON BANK FINANCIAL ACTIVITIES Important Disclaimer This translation has been generously provided by the Financial Regulatory Commission of Mongolia. This does not constitute an official
More informationThe Charitable Incorporated Organisation
The Charitable Incorporated Organisation October 2012 1 The Charitable Incorporated Organisation Introduction Nick Hurd, Minister for Civil Society, made the following announcement on 30 October 2012 on
More informationSM&CR Roundtable Questions
SM&CR Roundtable Questions Pollyanna Deane Felix Zimmermann Richard Sims Andrea Finn Laura Allen 27 September 2017 SMCR for insurers and insurance distributors 1. Different approaches SMCR for insurers
More informationDonations and loans to Members of the UK Parliament
Situations and Procedures Donations and loans to Members of the UK Parliament This document explains how donations and loans to Members of the UK Parliament are regulated. Contents: Overview of donations
More informationQ&A for LGPS Pension Funds Version issue date 10 July 2015
Q&A for LGPS Pension Funds Version 1.1 - issue date 10 July 2015 Transfers from the LGPS to Defined Contribution Schemes from 6 April 2015 Introduction The 2014 Budget announced reforms to workplace pensions
More informationOPTIONS FOR GIG ROWING CLUBS: LEGAL STRUCTURES
OPTIONS FOR GIG ROWING CLUBS: LEGAL STRUCTURES This note guide sets out some of the options for gig rowing clubs as to their possible legal structure. This guidance note does not constitute legal advice
More informationAn overview of charity campaigning & the Electoral Commission guidance
An overview of charity campaigning & the Electoral Commission guidance 1. Introduction 1.1 This note explores charity law and electoral law in the context of a charity involved in campaigning, following
More informationMAKING TAX DIGITAL: INTEREST HARMONISATION AND SANCTIONS FOR LATE PAYMENT
ICAEW REPRESENTATION 29/18 MAKING TAX DIGITAL: INTEREST HARMONISATION AND ICAEW welcomes the opportunity to comment on the Making Tax Digital: interest harmonisation and sanctions for late payment consultation
More informationLEGAL STATUS GUIDANCE
LEGAL STATUS GUIDANCE The Purpose of this Toolkit This toolkit is aimed for basketball clubs in Scotland who require to distinguish an appropriate legal structure for their club. There are various benefits
More informationConsumer Credit sourcebook. Chapter 4. Pre-contractual requirements
Consumer Credit sourcebook Chapter Pre-contractual CONC : Pre-contractual Section.2 : Pre-contract disclosure and.2 Pre-contract disclosure and.2.1 Application This section, unless otherwise stated in
More informationCourt of Appeal refuses permission to appeal in by way of business FCA lending authorisation exemption case by family run business to a builder
Court of Appeal refuses permission to appeal in by way of business FCA lending authorisation exemption case by family run business to a builder Newmafruit Farms Limited v. Alan Pither A2/2016/3778 Article
More informationCompany & business names
https://www.businesscompanion.info/en/quick-guides/miscellaneous/company-andbusiness-names Company & business names In the guide Who do the business names provisions apply to? Part 1: sole traders & partnerships
More informationStandard Mortgage Terms and Conditions. May 2018 Edition
Standard Mortgage Terms and Conditions May 2018 Edition Terms and Conditions Mortgages Contents Introduction 03 Definitions 04 Interpretation and application 05 Acting in joint names 05 Withdrawal of offer
More informationGuidance on credit-related regulated activities
Guidance on credit-related regulated activities The following provides guidance on the credit-related regulated activities that a consumer credit firm may undertake under the arrangements set out in the
More informationenlightened lending Mortgages for rental properties
enlightened lending Buy-to-let mortgages Mortgages for rental properties For further information Call 01535 650 770 Email mortgages@ecology.co.uk or write to the address below 09/17 7 Belton Road, Silsden,
More informationApplication Form ScottishPower Hardship Fund
Application Form ScottishPower Hardship Fund ALTERNATIVELY, APPLY ONLINE AT www.sedhardship.fund BEFORE COMPLETING THIS FORM, PLEASE CAREFULLY READ THE NOTES BELOW WHO CAN APPLY FOR AN AWARD? ScottishPower
More informationIndividual Voluntary Arrangements (IVAs)
BRIEFING PAPER Number CPB5165, 6 April 2016 Individual Voluntary Arrangements (IVAs) By Lorraine Conway Inside: 1. Introduction 2. Alternatives to bankruptcy 3. Characteristics of an IVA 4. Who is eligible
More informationLocal Government Pension Scheme (LGPS) Guidance on the creation and operation of Local Pension Boards in England and Wales
Local Government Pension Scheme (LGPS) Guidance on the creation and operation of Local Pension Boards in England and Wales LGPS Local Pension Board Guidance Last updated: 28 January 2015 1 INTRODUCTION...
More informationFINAL NOTICE. Darren Lee Newton. 22 Silverston Drive, Manchester M40 1WF. Date: 20 December ACTION
FINAL NOTICE To: Darren Lee Newton Address: 22 Silverston Drive, Manchester M40 1WF Date: 20 December 2018 1. ACTION 1.1. For the reasons given in this Notice and pursuant to section 56 of the Act, the
More informationFCA Consumer Credit Regime Licensing and Compliance Conference
FCA Consumer Credit Regime Licensing and Compliance Conference 4 December 2013 Agenda 09:30 Registration 10:00 Welcome Gerry Keaney, Chief Executive - BVRLA 10:05 About the BVRLA Gerry Keaney, Chief Executive
More informationResponse to the HM Revenue & Customs consultation on whether to bring illegal waste sites within the scope of the Landfill Tax, March 2017
Response to the HM Revenue & Customs consultation on whether to bring illegal waste sites within the scope of the Landfill Tax, March 2017 1. The UK Environmental Law Association ( UKELA ) aims to make
More informationHMRC Reviews & Enquiries
HMRC Reviews & Enquiries A guide for clients www.bwm.co.uk 0151 236 1494 HMRC Reviews & Enquiries HMRC has the right to investigate any tax return submitted by any taxpayer. The department has considerable
More information