Advertisement by Julian Harris Do you have a clear plan of action in respect of the FCA taking over regulation of Consumer Credit from April? Please see below 1) if you're not currently authorised by the FCA 2) if you are currently authorised by the FCA www.julianharris.net info@julianharris.net Apply to join our network at no cost (IFA, MA or Ins only) 1) If you currently carry out consumer credit activities, but are not FCA regulated, please talk to us, as we are offering a route for you to become authorised via us for consumer credit activities (you may also expand your authorisation to other regulated activities).  A brief list of our offering is below:- Due Diligence checks on individuals involved in business. Carry out compliance checks on client files in the same manner as we do for 1st charge mortgages (via our Intranet system).  It is expected that the FCA will treat them in the same way as they are treated in Europe.  Suitability, affordability and transparency.  Evidence of income. Review of past business and processes to ensure no breaches of the law. We would offer AR status or compliance consultation service.  Our rates are very competitive with no monthly fee. The FCA detailed rules are not expected until sometime in 2015.  We would adapt our offering in line with the FCA published rules. Compliance checking of Financial Promotions (adverts, mail-merges, websites etc.). Dealing with FOS where required. Ensure advisers meet "Fit and Proper" requirements. AML compliance. New 14 day cooling off period proposed. Interpretation of the new FCA Consumer Credit sourcebook (in the interim the OFT standards will be adapted). Interpretation of the FCA's consultation paper CP13/10. FCA policy statement expected February 2014. Interim permission advice.  If you have a CCL you can apply for interim permission now.  If you do not have a CCL you can apply for FCA Consumer Credit Authorisation from 1 April 2014.  If you wish to become an AR for Consumer Credit Authorisation we can apply to register you after 1 April 2014.  If being an AR is your preferred option, you will still need to apply for interim permission, otherwise you would have a period (likely to run into months) from 1 April 2014 where you would be unable to carry out Consumer Credit related activities. 2) If you are currently authorised by the FCA for other activities, do you have a clear understanding of your responsibility in the advisory process?  For instance, you may be introducing loan business to a third party whom take responsibility for advice of the loan itself, but it may be that you were the one that completed the Factfind and advised the client that the loan option was the best for them compared with their options (such as remortgage, further advance overdraft, unsecured loan etc.).  It may be that following underwriting the interest rate is much higher than expected.  This scenario could leave you exposed in terms of advice liability, PI cover, complaints etc. Our approach moving forward is to compliance check the whole advisory process, including the part carried out by the loan broker.  Are you happy with your approach/the guidance given by your current Network? If you would like to discuss your options in respect of either of the above or any other matter, please do not hesitate to contact us. Call Peter Welsh, Business Development Executive on 07789 446798 or Julian Harris, CEO on 07715 182328 www.julianharris.net               info@julianharris.net Download our brochure Services Fees Recruitment Contact Us
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