FCA Compliance for Consumer Credit Firms

Scope follows the firm's permissions and business model. A typical review covers governance and monitoring, financial promotions, pre-contract disclosure, creditworthiness and affordability assessment, treatment of customers in financial difficulty, collections and forbearance, complaints handling and root cause analysis, vulnerable customer arrangements, Consumer Duty outcome evidence, appointed representative oversight where relevant and regulatory reporting.

Beyond the Principles and Consumer Duty, CONC sets out detailed conduct requirements. In supervisory terms the recurring areas of focus are whether lending decisions are genuinely affordable for the customer, whether customers in difficulty are identified early and offered appropriate forbearance, whether collections practice is fair, whether promotions are clear and not misleading and whether the firm can evidence outcomes rather than intentions.

Yes. We review lending policy and its practical application, the affordability methodology, treatment of income and expenditure data, use of credit reference and open banking data, override and exception handling, and the evidence retained on file. We test a sample of decisions rather than relying on the documented process alone.

All four outcomes apply. In practice the most testing areas are price and value, where firms must be able to justify total cost against the benefits delivered, and consumer support, where the FCA expects customers in financial difficulty to receive appropriate help without unreasonable barriers. Outcome monitoring must be capable of showing where results differ across customer groups.

Yes. We review strategy, contact practice, agent scripts and behaviour, quality assurance, forbearance options and their availability in practice, treatment of vulnerable customers, third party collection oversight and the management information used to monitor outcomes.

Yes. We support pre-appointment due diligence, onboarding, scope of appointment, ongoing monitoring and testing, financial promotions oversight, annual reviews, notifications, offboarding and remediation of historic weaknesses.

Yes. Retained support provides continuing access to senior regulatory expertise alongside the firm's existing team, covering scheduled monitoring input, technical questions, regulatory change, policy review, board reporting and oversight of remediation.