Contact details.
|
|
- Georgia Webb
- 5 years ago
- Views:
Transcription
1 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 Credit Unions Limited (ABCUL) Contact details Mark Lyonette Chief Executive mark.lyonette@abcul.org Or Abbie Shelton Policy & Communications Manager abbie.shelton@abcul.org Tel:
2 Introduction We appreciate the opportunity to respond to this consultation. The Association of British Credit Unions Limited (ABCUL) is the main trade association for credit unions in England, Scotland and Wales representing around 65% of British credit unions who in turn serve around 80% of credit union members. Credit unions are not-for-profit, financial co-operatives owned and controlled by their members and operated for their sole benefit. They provide inclusive financial services to the whole of their communities including safe savings and affordable loans. An increasing number of credit unions also offer more sophisticated products such as current accounts, ISAs and mortgages. At 30 September 2012, credit unions in Great Britain were providing financial services to 883,670 adult members and held more than 795 million in deposits with more than 605 million out on loan to members. An additional 122,379 young people were saving with credit unions. 1 Credit unions work to provide inclusive financial services has been valued by successive Governments. Credit unions participation in the Growth Fund from saw over 400,000 affordable loans made valuing 175 million 2 and saving consumers between 119 million and 135 million. 3 The DWP recently announced that it has awarded a contract for the delivery of its Credit Union Expansion Project, to a consortium of credit unions led by ABCUL. The Project will invest up to 38 million in the sector. 4 Summary of response Credit unions are generally not required to be licensed under the Consumer Credit Act since they enjoy an exemption for debtor-creditor agreements under the Consumer Credit (Exempt Agreements) Order 1985 as amended in This exemption is provided on the basis that credit unions provide consumer credit, uniquely in the UK, under an interest rate ceiling and in competition with higher-cost alternatives. Considerations of proportionality are therefore central to credit unions current treatment under the Consumer Credit Act as regulated by the OFT. However, for some consumer credit activity such as debtor-creditor-supplier agreements or debt advice credit unions are required to be licensed and, as such, many are. It is on this basis that we welcome the broad outline of the transfer of responsibility for consumer credit as set out in the consultation. In particular we welcome the proposal to broadly maintain the scope of consumer credit regulation under the FCA regime and to retain pre-existing exemptions. While we would accept that the credit union exemption for debtor-creditor agreements might be something which is reconsidered over the long term, we feel strongly that now would not be the 1 Figures from unaudited quarterly returns provided to the Financial Services 2 See DWP Growth Fund statistics, here: 3 See Independent evaluation of the Growth Fund, here: 4 See DWP Press Release here:
3 right time to withdraw the concession. The present context of financial regulatory reform and the ever-increasing costs of regulation is impacting upon all financial firms. For credit unions to cope with these reforms and live up to the expansion ambitions the Government has for the sector would be made much more difficult than it ought to be were the consumer credit exemption withdrawn at this time. Elsewhere, we are particularly pleased that it is proposed that proportionality will be a central principle in the reformed FCA regime for consumer credit. We are very keen that all steps are taken to ensure that smaller firms, such as credit unions, are afforded a flexible and proportionate approach to ensure that inappropriate regulatory burdens do not unduly restrict the supply of credit. This is particularly important in the credit union sector where steps are being taken to expand the role that credit unions can play in providing credit in competition with high-cost alternatives, such as pay day lenders, which have caused so much concern and controversy in recent years. Similarly, we are happy with the gradual approach that the Government has adopted for these reforms while intervening proactively in the area of high-cost credit and payday lending which is a particular concern to many of our members. The interim period of two years and concurrent review of the consumer credit regime by FCA should help to ensure that a fit-for-purpose regime is established without causing any undue disruption or confusion in the consumer credit market. Consultation questions Conduct requirements and rules Q1. What are your views on the Government s proposal to carry forward CCA conduct requirements which cannot be easily replicated in FCA rules? Do you agree with the Government s intention to require the FCA to review these retained CCA provisions, with a view to moving to rules-based alternatives wherever possible? We are in general agreement with the proposals here. It seems sensible to us to minimise upheaval and ensure that an appropriate regime is established through approaching these reforms gradually and giving the FCA time to consider what powers it ought to take over a number of years. Given that the review will result in required legislative measures, though, we would suggest that the Government should consult on the FCA's recommendations once its period of review concludes in We are also broadly supportive of the general principle that as much of the regime should be instituted under a rules-based system in order to cement a more responsive and flexible approach which can, in future, take action to address emerging trends much more readily than the legislation-based regime has been to this point. It is important within this, though, that the rulesbased regime follows a full consultation process and is clearly accountable and transparent. Q2. How, if at all, do you think industry codes can complement FCA conduct regulation?
4 We feel that industry codes can play an important role in improving standards and consistency in the market. They can also complement the role of a statutory regulator by driving up standards where a regulatory measure might be considered too heavy-handed. However, we also feel that there are significant limitations to voluntary codes, not least the fact that they do not necessarily apply to all market participants, and that the new regime should be ready to act through regulation where voluntary codes are seen to be failing. Authorisation Q3. What are your views on the Government s proposals for the two tier authorisation regime? Is the scope of the limited permission regime right? We are supportive of the general approach in instituting a two tier regime which permits those firms for whom consumer credit is ancillary to their primary (non-financial) business a more lenient regime. We would suggest, though, that certain activities which credit unions currently undertake such as informal debt advice for members who have become over-indebted should also be classified in tier two as limited permission activity. Generally this will consist of providing guidance on relieving the burden of unmanageable debt in line with credit unions co-operative ethos and social mission but has, by the OFT, been considered high-risk licensable activity. Q4. What are your views on the proposed changes to the appointed representatives regime? We have no view. Q5. What are your views on the proposed approach for dealing with those currently covered by group licences? We have no view other than to make the point once again that the debt advice work which credit unions often engage in auxiliary to their core business should be considered not-for-profit debt advice and be open to the same treatment as those organisations which perform this service as their primary function. Credit unions only engage in this work informally as part of their social mission and we do not feel it is appropriate that the current categorisation of this as a for-profit, high-risk service is appropriate. Scope of regulation Q6. What are your views on the Government s proposals for scope of regulation, including changes in respect of credit intermediation, tracing agents and credit reference agencies? We strongly support the Government's proposals for the scope of regulation, particularly retaining pre-existing exemptions such as that enjoyed by credit unions for debtor-creditor agreements. Credit unions enjoy this exemption in recognition both of the fact that they provide credit to their
5 members, uniquely, under an interest rate ceiling and also because of their co-operative, social mission to provide credit on affordable terms in competition with high-cost alternatives. If the new regime is to meet the proportionality principle which the Government has set for it, the retention of this exemption is vital. While we would accept that in the long term the exemption may not be retained indefinitely, today's context of rising costs of regulation coupled with the ambitious plans for expansion of the sector which the Government is pushing forward elsewhere, necessitate the continued proportionate treatment of credit unions in consumer credit regulation. To withdraw the exemption and add another layer of regulation would seriously hamper credit unions' ability to meet the expectations that are, rightly, being placed upon them. Q7. Are there any exemptions that are to be carried forward that should be reconsidered? We have no views about exemptions which should be reconsidered. We do, however, reiterate our support for the retention of the credit union exemption for debtor-creditor agreements which is of great importance to assisting the credit union sector in rising to the ambitious expansion objectives which the Government has given it. Q8. What are your views on the proposed new activity to capture the activities of peer to peer platforms? No view. Q9. Do consultation respondents have any data on the activity of lead generators in the debt management sector? What detriment is being cause by these firms? And what are your views on a suitable regulatory response? Our members have concerns about some of these firms. Lead generation can serve to exacerbate problems of over-indebtedness by pushing vulnerable consumers towards debt which they may not be able to manage. We would suggest that such firms are brought under the regulatory purview and that steps are taken to improve standards in the industry, such as the information that is given to consumers about how their data will be used. Enforcement and redress Q10. What are your views on the Government s proposal to repeal many of the criminal offences in the CCA and make breaches of these requirements, once in rules, subject to the FCA s enforcement toolkit? We have no strong views here. Interim permissions Q11. What are your views on the proposed interim permissions regime?
6 We are broadly satisfied with the interim permissions regime as proposed. It will be important that special efforts are taken to ensure that the arrangements surrounding the interim period are clear to regulated firms, particularly the dates by which they are required to seek full authorisation. Q12. If you are operating a peer to peer platform and do not hold an OFT licence, what are your views on the transitional arrangements for peer to peer platforms? Not applicable. ABCUL April 2013
FCA 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 informationOffice of Fair Trading Annual Plan consultation document
Office of Fair Trading Annual Plan consultation document 2012-13 Response from Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications Manager abbie.shelton@abcul.org
More informationHM Treasury & Department for Business, Innovation and Skills
HM Treasury & Department for Business, Innovation and Skills A new approach to financial regulation: consultation on reforming the consumer Response from the Association of British Credit Unions Limited
More informationFinancial Services Authority CP11/29 Deposit protection: raising consumer awareness
Financial Services Authority CP11/29 Deposit protection: raising consumer awareness Response from the Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications
More informationFinancial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. Dear sir / madam. Payment systems regulation call for inputs
Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Dear sir / madam Payment systems regulation call for inputs We appreciate the opportunity to respond to this consultation.
More informationADVICE NOTE FIRST EDITION (NOVEMBER 2013)
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
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 informationFCA Regulatory fees and levies: policy proposals for 2014/15
FCA Regulatory fees and levies: policy proposals for Response by the Money Advice Trust Date: JANUARY 2014 Contents Page 2 Page 3 Page 4 Page 5 Contents Introduction / About the Money Advice Trust Introductory
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 informationCaroline Russell AM Economy Committee London Assembly City Hall The Queen s Walk London, SE1 2AA. 28 September 2017
Caroline Russell AM Economy Committee London Assembly City Hall The Queen s Walk London, SE1 2AA 28 September 2017 Dear Caroline & the Economy Committee The Mayor s role in promoting and supporting financial
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 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 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 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 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 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 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 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 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 informationIntroduction / About the Money Advice Trust Introductory Comment Responses to individual questions
Page 2 Page 3 Page 4 Page 6 Contents Introduction / About the Money Advice Trust Introductory Comment Responses to individual questions The Money Advice Trust is a charity founded in 1991 to help people
More informationBSA Response to FCA Loan-based ('peer -topeer') platforms consultation. CP18/20. Restricted 25 October 2018
BSA Response to FCA Loan-based ('peer -topeer') and investmentbased crowdfunding platforms consultation. CP18/20 Restricted 25 October 2018 Introduction The Building Societies Association (BSA) represents
More informationISA qualifying investments: including peer-to-peer loans HM Treasury
ISA qualifying investments: including peer-to-peer loans HM Treasury Visualise your business future with Altus Consulting Reference HMT/P2PISA/RESP Date 09/12/2014 Issue 1.0 Author Bruce Davidson Security
More informationConsultation response: FCA Pension reforms
Consultation response: FCA Pension reforms Response by the Money Advice Trust Date: January 2016 Contents Page 2 Page 3 Page 4 Page 6 Contents Introduction / About the Money Advice Trust Introductory comment
More informationCP17/27: Assessing creditworthiness in consumer credit
Consultation response CP17/27: Assessing creditworthiness in consumer credit Response from the Joseph Surtees, Policy Manager joseph.surtees@ Tel: 0207 943 0018 1. About us 1.1. The (MAS) is a UK-wide,
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 informationFinancial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. 26 January 2018
Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 26 January 2018 (Uploaded at the Financial Conduct Authority s website) Dear Sir/Madam, Standard Chartered s Response to the
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 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 informationCRS Seminar 9 th December
Legal and Regulatory Issues Monica Gogna Ropes & Gray @uktisa ISAs and P2P Loans: Legal and Regulatory Issues Monica Gogna, Partner LLP Introduction Today s topics: Overview of the background to UK peerto-peer
More informationIndividual Accountability: Extending the Senior Managers & Certification Regime to all FCA firms
Individual Accountability: Extending the Senior Managers & Certification Regime to all FCA firms 3 rd November 2017 On behalf of their members, AFME and UK Finance welcome the opportunity to comment on
More informationConsultation response: Financial Capability Strategy for the UK
Consultation response: Financial Capability Strategy for the UK Response by the Money Advice Trust Date: October 2014 Contents Page 2 Page 3 Page 4 Page 5 Contents Introduction / About the Money Advice
More informationCIH Briefing on the White Paper for Welfare Reform. Universal Credit: welfare that works
CIH Briefing on the White Paper for Welfare Reform Universal Credit: welfare that works November 2010 1) Introduction The government has published its White Paper on welfare reform which sets out its proposals
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 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 informationFeedback Statement on CP109 Consultation on Potential Changes to the Investment Framework for Credit Unions
Feedback Statement on CP109 Consultation on Potential Changes to the Investment Framework for Credit Unions 1 Table of Contents Foreword... 2 1. Introduction... 4 2. Executive Summary... 6 3. Responses
More informationAdvice NI Response to the Office of Fair Trading s Power to suspend Consumer Credit Licenses Draft OFT guidance for licence holders.
Advice NI Response to the Office of Fair Trading s Power to suspend Consumer Credit Licenses Draft OFT guidance for licence holders. Deadline: 15 th January 2013 Advice NI welcomes the opportunity to respond
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 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 informationEquity Release Council response to Financial Conduct Authority CP17/32: Quarterly Consultation Paper No.18
Equity Release Council response to Financial Conduct Authority CP17/32: Quarterly Consultation Paper No.18 Introduction The Equity Release Council is the industry body for the equity release sector. The
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 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 information14 November 2014 Better workplace pensions: Putting savers interests first
provided by B&CE 14 November 2014 Better workplace pensions: Putting savers interests first About B&CE B&CE is the not-for-profit provider of The People s Pension. It manages assets of 2.2 billion with
More informationEnergy Saving Trust consultation response: Voluntary redress payments (Ofgem)
Energy Saving Trust consultation response: Voluntary redress payments (Ofgem) Energy Saving Trust is pleased to respond to Ofgem s consultation on the allocation of voluntary redress payments in the context
More informationBBA RESPONSE TO JOINT COMMITTEE CONSULTATION PAPER ON GUIDELINES FOR CROSS-SELLING PRACTICES JC/CP/2014/05
20 March 2015 BBA RESPONSE TO JOINT COMMITTEE CONSULTATION PAPER ON GUIDELINES FOR CROSS-SELLING PRACTICES JC/CP/2014/05 1. The British Bankers Association ( BBA ) welcomes the opportunity to respond to
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 informationReview of the Money Laundering Regulations 2007: The Government Response
Response to the HM Treasury consultation paper Review of the Money Laundering Regulations 2007: The Government Response September 2011 Fraud Advisory Panel Registered office: Chartered Accountants Hall,
More informationFSA Consultation CP 13/7: High-level proposals for an FCA regime for consumer credit
FSA Consultation CP 13/7: High-level proposals for an FCA regime for consumer credit The ABI s Response to the FSA consultation on transferring consumer credit regulation to the Financial Conduct Authority
More informationDavid Malcolm Strategy & Competition Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 08 February 2017
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk David Malcolm Strategy & Competition Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 08 February 2017 Dear David, Call
More informationRetail Finance Seminar Call for Input: Review of retained provisions of the Consumer Credit Act
Retail Finance Seminar Call for Input: Review of retained provisions of the Consumer Credit Act 10 and 17 May 2016 Jo Owens Principal Associate Call for Input What is it? What is the Call for Input? FCA
More informationProtection of Vulnerable Groups (Scotland) Act 2007
Protection of Vulnerable Groups (Scotland) Act 2007 Consultations on Implementation UNISON Scotland s response to Scottish Executive Consultations on Implementation of the February 2010 Executive Summary
More informationThe distinct nature of insurance business and the introduction of a specific insurance objective;
Financial Regulation Strategy HM Treasury 1 Horse Guards Road London SW1A 2HQ Via Email: financial.reform@hmtreasury.gsi.gov.uk 8 September 2011 Dear Sirs A new approach to financial regulation: the blueprint
More informationSTANDARD TERMS OF BUSINESS
STANDARD TERMS OF BUSINESS The purpose of this schedule is to set out the standard terms of business that apply to all engagements accepted. All work carried out is subject to these terms except where
More informationInvestor Key Information Understanding your investment
Key Information and Investor Terms Investor Key Information Understanding your investment You should read the following information and the Investor Terms (below) carefully before making your investment.
More informationThe Standards of Lending Practice. Business Customers
The Standards of Lending Practice Business Customers Introduction The Standards of Lending Practice for business customers, which replace the micro enterprise provisions of the Lending Code, are composed
More informationUK Asset Resolution Limited Group. Interim Financial Report
UK Asset Resolution Limited Interim Financial Report 30 September 2017 UK Asset Resolution Limited Group Interim Financial Report for the 6 months to 30 September 2017 30 November 2017 UKAR Interim Financial
More informationCROWDFUNDING AND THE PROMOTION OF NON-READILY REALISABLE SECURITIES INSTRUMENT 2014
CROWDFUNDING AND THE PROMOTION OF NON-READILY REALISABLE SECURITIES INSTRUMENT 2014 Powers exercised A. The Financial Conduct Authority makes this instrument in the exercise of the following powers and
More informationProtected Trust Deeds Consultation Response
Protected Trust Deeds Improving the Process Consultation by the Scottish Government Response from the Association of British Credit Unions Limited (ABCUL) January 2012 Contact: Frank McKillop Policy &
More informationThe Improvement Service ELECTED MEMBER BRIEFING NOTE. Affordable Credit
The Improvement Service ELECTED MEMBER BRIEFING NOTE Affordable Credit What is the purpose of the briefing note series? The Improvement Service (IS) has developed an Elected Members Briefing Series to
More information12 January Contents Page
12 January 2016 Memorandum of Understanding between the Competition and Markets Authority and the Financial Conduct Authority on the use of concurrent powers under consumer protection legislation Contents
More informationStepChange Debt Charity response to the Banking Standards Board consultation: What do good banking outcomes look like to consumers?
StepChange Debt Charity response to the Banking Standards Board consultation: What do good banking outcomes look like to consumers? January 2018 StepChange Debt Charity London Office 6th Floor, Lynton
More informationHM Treasury s consultation on amending the definition of financial advice
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Assets, Savings and Consumers HM Treasury 1 Horse Guards Road London SW1A 2HQ 15 November 2016 Dear Sir, Madam, HM Treasury s consultation on amending
More informationPilchConnect submission to the Treasury Consultation Paper: Better targeting of NFP tax concessions
PilchConnect submission to the Treasury Consultation Paper: Better targeting of NFP tax concessions July 2011 Endorsements This submission is endorsed by the following organisations: Victorian Council
More informationICAEW WRITTEN SUBMISSION
ICAEW WRITTEN SUBMISSION BIS COMMITTEE: THE INSOLVENCY SERVICE Written evidence submitted on 6 January 2012 Contents Paragraph Introduction 1 Who we are 2 5 Executive summary 6 Context 7 9 Pre-pack administrations
More informationCONTENTS TOB.MP.INT.RES.6.0 2
Terms Of Business {Name of adviser}. {Name of firm XXXX Ltd}. Address they will conduct business from. {Name of firm} is an Appointed Representative of {Intrinsic Mortgage Planning / Intrinsic Financial
More informationResponse from the Solicitors Regulation Authority
Legal Services Board / Legal Ombudsman consultation: The Levy: funding legal services oversight regulation Response from the Solicitors Regulation Authority September 2010 Legal Services Board / Legal
More informationConsultation Response Office of Fair Trading: Proposals Payday Lending, Consultation on a Market Investigation Reference March 2013
Consultation Response Office of Fair Trading: Proposals Payday Lending, Consultation on a Market Investigation Reference March 2013 Who we are Toynbee Hall has worked on the frontline in the struggle against
More informationReview of the Money Advice Service
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Independent Money Advice Service Review 1 Horse Guards Road London SW1A 2HQ 1 September 2014 Review of the Money Advice Service This is the Financial
More informationDebt advice works: Measuring the effectiveness of crisis interventions. Lesley Robinson 12 December 2014
Debt advice works: Measuring the effectiveness of crisis interventions Lesley Robinson 12 December 2014 1 Agenda About Money Advice Service MAS and Debt Advice Sector Impact of Debt Advice Looking Ahead:
More informationOPERATING GUIDELINES BETWEEN THE FINANCIAL CONDUCT AUTHORITY AND THE PANEL ON TAKEOVERS AND MERGERS ON MARKET MISCONDUCT
Agreed version: 8 July 2016 OPERATING GUIDELINES BETWEEN THE FINANCIAL CONDUCT AUTHORITY AND THE PANEL ON TAKEOVERS AND MERGERS ON MARKET MISCONDUCT A. Purpose, status and application of the guidelines
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 informationINVESTOR GUIDE ISAs AND JISAs
INVESTOR GUIDE ISAs AND JISAs COLUMBIATHREADNEEDLE.CO.UK 1 OVERVIEW Individual Savings Accounts (ISAs) and Junior ISAs (JISAs) are tax-efficient ways to save or invest. They are wrappers that protect your
More informationInnovative Finance ISA Key Information
Innovative Finance ISA Key Information April 2018 The purpose of this ISA Investor Key Information document is to focus your attention on some of the important things you should know before deciding to
More informationMABS National Development Limited. Review of the Code of Conduct on Mortgage Arrears
MABS National Development Limited Review of the Code of Conduct on Submission of the Money Advice and Budgeting Service September 2010 Introduction The Money Advice and Budgeting Service (MABS) was established
More informationA guide to your second charge mortgage
Second charge mortgages DECEMBER 2016 A guide to your second charge mortgage Mortgage terms and conditions Introduction This booklet contains the second charge mortgage terms and conditions for Paragon
More informationESMA s policy orientations on possible implementing measures under the Market Abuse Regulation
24 January 2014 European Securities and Markets Authority 103 rue de Grenelle 75007 Paris France Submitted online at: www.esma.europa.eu RE: ESMA s policy orientations on possible implementing measures
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 information1 March Dear CEO. Second charge lenders and responsible lending
1 March 2018 Dear CEO Second charge lenders and responsible lending I am asking you as a CEO of a firm that enters into regulated second charge mortgage contracts to review your mortgage lending processes
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 informationTerms of Business Mortgage & Protection Services
Terms of Business Mortgage & Protection Services Oaklands Business Centre Hooton Road, Hooton Cheshire, CH66 7NZ. T: 0151 328 5678 E: info@chesterpartnership.co.uk W: www.chesterpartnership.co.uk Introduction
More informationmeters installed under warrant: final proposals
StepChange Debt Charity response to the Ofgem consultation: Prepayment meters installed under warrant: final proposals November 2016 StepChange Debt Charity London Office 6 th Floor, Lynton House, 7-12
More informationConsultation Paper - Draft technical standards under the Benchmarks Regulation
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax ihsmarkit.com ESMA 103 rue de Grenelle 75007 Paris, France Submitted online www.esma.europa.eu
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 informationBreathing Space Scheme R3 response January 2019
Breathing Space Scheme R3 response January 2019 ABOUT R3 1. R3 is the trade association for the UK s insolvency, restructuring, advisory, and turnaround professionals. We represent licensed insolvency
More informationCONTENTS TOB.MP.INT.RES.5.0 2
Terms Of Business Mark Gregory Ltd 1 st & 2 nd Floor, 53 High Street, Aylesbury, Bucks, HP20 1SA Mark Gregory is an Appointed Representative of Intrinsic Mortgage Planning who are authorised and regulated
More informationA Users Guide to the recast Late Payment Directive
DIRECTIVE 2011/7/EU ON COMBATING LATE PAYMENT IN COMMERCIAL TRANSACTIONS A Users Guide to the recast Late Payment Directive MARCH 2013 Contents Contents.2 Summary...3 Summary of new measures 4 What is
More informationMr W says CashEuroNet UK LLC, trading as QuickQuid, lent to him irresponsibly.
complaint Mr W says CashEuroNet UK LLC, trading as QuickQuid, lent to him irresponsibly. background I sent both parties my provisional decision on this complaint on 12 March 2019. A copy of it is attached
More informationConsumer Credit sourcebook. Chapter 7. Arrears, default and recovery (including repossessions)
Consumer Credit sourcebook Chapter Arrears, default and recovery (including CONC : Arrears, default and Section.1 : Application.1 Application.1.1 Who? What? This chapter applies, unless otherwise stated
More informationRegulatory reform of UK Financial Services
Regulatory reform of UK Financial Services Regulatory reform of UK Financial Services Introduction As a result of the financial crisis in 2008, the government announced its intention to reform the regulatory
More informationCP14/06 - Regulated fees and levies: Rates proposals 2014/15
CP14/06 - Regulated fees and levies: Rates proposals 2014/15 This response is submitted on behalf of the Association of Mortgage Intermediaries (AMI). AMI is the trade association representing over 80%
More informationA New European Regime for Venture Capital
Ref. Ares(2011)1001117-21/09/2011 A New European Regime for Venture Capital Response of the Law Society of England and Wales ETI Registration number: 24118193117-34 The Law Society of England and Wales
More informationUK Banking & Capital Markets Budget Alert
Summer Budget 2015 UK Banking & Capital Markets Budget Alert Headlines The UK Budget announcements herald a major shift in banking tax policy, with the UK Government attempting to respond to industry concerns
More informationCapital Requirements Directive 4: consultation on country-by-country reporting
CBCR consultation Financial Services Group Floor 1, Red HM Treasury 1 Horse Guards Road London, SW1A 2HQ Email: CBCRconsultation@hmtreasury.gsi.gov.uk 18 October 2013 Dear Ali, Capital Requirements Directive
More informationFCA PRUDENTIAL TRANSITIONAL DIRECTION
FCA PRUDENTIAL TRANSITIONAL DIRECTION 1 Part 1: The FCA prudential transitional direction 1.1 D This direction is made by the FCA under Part 7 of the Financial Services and Markets Act 2000 (Amendment)
More informationWhat sort of credit can help low income households?
March 2018 What sort of credit can help low income households? A segmentation of the need for affordable credit Introduction Too many families on low incomes have to turn to high cost credit as a safety
More informationDirect line: Local fax:
Direct line: 0207 066 3100 Local fax: 0207 066 3101 Email: martin.wheatley@fca.org.uk Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Andrew Tyrie MP Chairman of the Treasury
More informationTelephone: Janet Brown & Marta Alonso Financial Conduct Authority 12 Endeavour Square London E20 1JN
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Janet Brown & Marta Alonso Financial Conduct Authority 12 Endeavour Square London E20 1JN 24 October 2018 By email to: cp18-20@fca.org.uk Dear Janet
More informationEquity Release Council
Equity Release Council Autumn 2018 Market Report Contents Key findings 4. Market context Public sentiment towards property as a safe way to save for retirement improves since 2010/12 Number of homes bought
More informationHMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on UK Immovable Properties
James Konya NRCG Consultation HM Revenue & Customs Room 3C/04 100 Parliament Street London SW1A 2BQ 15 February 2018 Dear James HMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on
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 informationRetirement Investments Retirement Insurance Health Investments Insurance Health
Retirement Investments Insurance Health Investment Portfolio Investment Portfolio from Aviva Whatever your financial needs, Investment Portfolio offers you a wide range of investment options, giving you
More information