The FCA’s final landing slot for consumer credit authorisations and variations of permission has opened. The landing slot will expire on 31 March 2016. All firms with interim permissions, who have not yet submitted an authorisation or variation of permission application and who intend on engaging in credit-related regulated activities beyond 1 April 2016, must now prepare their authorisation application for submission.

Firms who have successfully applied to have their landing slot postponed will find that the FCA is unsympathetic to delayed submissions, or incomplete documentation.

Firms should begin the process of assembling the relevant information, and ensure that compliance procedures and documentation are properly thought through. We have found that some firms often underestimate the scale of the task in embedding cultural change within organisations, as they take on board FCA principles. Reflecting this in appropriate policies and procedures is important. A number of firms have usefully undertaken training for particular staff members, to ensure that they are competent and capable of meeting the FCA’s new rules and guidance for consumer credit firms.

The FCA has now had almost two years of experience in regulating the consumer credit market, in which time it has learnt a great deal about certain sectors of the market. The FCA continued investigations begun by the OFT into historic concerns in the market, and has broadened its spotlight to other areas of the wider market, and has introduced specific new rules in key areas such as credit broking. In our experience, some firms now going through authorisation face more challenging questions from the FCA on their business model as the regulator continues to develop its understanding of the market.