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Every regulated firm relies on third parties. Marketing agencies generate leads.  Cloud providers host critical systems.  Software providers automate decisions.  Debt collection agencies recover customer balances.  Compliance consultants provide specialist advice.  Many firms also rely on introducers, affiliates, credit reference agencies and technology partners to deliver key parts of the customer journey. Outsourcing has become...
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Most regulated firms organise compliance by regulator. The Financial Conduct Authority looks after financial services.  The Information Commissioner’s Office oversees data protection.  The Advertising Standards Authority monitors advertising.  The Financial Ombudsman Service considers complaints. Each has its own rules, guidance and expectations and operationally, that approach makes perfect sense. From a customer’s perspective, however, none...
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Good governance has never been about producing more paperwork. Policies, Board packs and committee terms of reference all have an important role to play, but they are only part of the picture. Increasingly, the Financial Conduct Authority is looking beyond governance structures and asking a more fundamental question. How effectively are those structures actually working?...
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Mention operational resilience to most consumer credit firms and the response is often the same. “That’s something the banks have to worry about.” It’s an understandable assumption. Much of the regulatory discussion around operational resilience has focused on larger financial institutions, critical business services and extensive resilience testing. For many lenders and brokers, it can...
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There was a time when a compliance monitoring plan was largely built around the FCA Handbook. Testing financial promotions.  Reviewing complaints.  Checking disclosures.  Sampling customer files.  Reporting breaches. Those activities remain important; the challenge is that regulation has moved on. Consumer Duty, data-led supervision, evolving governance expectations and greater scrutiny of customer outcomes have changed...
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If you ask most compliance professionals what has changed over the past few years, many will point to Consumer Duty, Buy Now Pay Later regulation or the Data (Use and Access) Act. Those developments have undoubtedly reshaped the regulatory landscape. Yet perhaps the biggest change has received far less attention. The FCA is not simply...
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For many FCA-regulated consumer credit firms, preparation for the next annual Consumer Duty Board Report should already be underway. The first round of Board Reports focused largely on implementation. Firms established governance frameworks, identified management information, embedded Consumer Duty into policies and began monitoring customer outcomes. This year’s reporting cycle is different. Recent publications and...
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The countdown is over. Buy Now Pay Later (BNPL) lending is now entering a new regulatory era, bringing millions of consumers and a rapidly growing sector firmly within the FCA’s regulatory framework. While much of the discussion over the past year has focused on what the legislation would look like, the emphasis now shifts to...
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Many firms approach FCA authorisation with a simple objective. Submit the application and move forward.   In practice, the question is more fundamental. Are you actually ready to operate as a regulated firm? The Financial Conduct Authority is not assessing whether a business idea is viable. It is assessing whether the firm is capable of delivering...
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