On 11 April 2025, there was published a record of the meeting that took place on 24 March 2025 between the Economic Secretary to the Treasury (EST), Emma Reynolds, and the Chief Executive of the Financial Conduct Authority (FCA), Nikhil Rathi, which discussed the December 2024 update to the FCA’s Perimeter Report.

The record notes that the Chief Executive of the FCA (CEO) raised the following:

• Non-Financial Spread Betting. The CEO noted that spread betting products which are based on non-financial indexes, such as sports or political performance, are not within scope of the FCA’s perimeter though there are some calls for them to be within the perimeter. He noted that consumers must be aware of the risks when purchasing such unregulated products. The EST agreed that the government and regulators should work together to ensure consumers understand the regulatory position and associated risks of these products and it should not be assumed that all such products should be regulated.
• Consumer Credit Act Reform. The CEO raised that some industry stakeholders would like the perimeter to be amended in relation to lending to small businesses, where the level of regulatory protection that a Small and Medium Enterprise borrower receives is dependent on its legal entity (combined with the loan amount). Currently under the Consumer Credit Act (CCA), lending under £25,000 to sole traders, partnerships with no more than three partners, and unincorporated associations, is in scope of the perimeter. However, lending to limited companies, LLPs and partnerships of more than three persons is out of scope of the perimeter, no matter the loan amount. The EST thanked the CEO for setting this out and noted that the Treasury will shortly be consulting on reforms to the CCA.
• Investment consultants. The CEO noted the value of good quality advice from investment consultants in supporting the government’s agenda, for example, on pensions reform. The EST noted that the Treasury will shortly be publishing a response to the Pensions Investment Review consultation and officials will engage with the FCA following publication.
• Appointed Representatives. The CEO noted that the poor quality of oversight by some principal firms over appointed representatives can be a source of significant consumer harm and noted that the FCA would welcome progress on next steps on whether wider legislative changes are needed following the Treasury’s Call for Evidence. The EST recognised the need to address potential consumer harm, while also striking a balance with ensuring burdens on firms are proportionate.