Are Credit Brokers FCA-Ready?
The FCA has increasingly focused on appointed representatives (ARs) in consumer credit, signalling that firms cannot outsource responsibility for compliance. Data from 2025 shows continued scrutiny on consumer harm, reporting failures, financial promotions, and governance weaknesses.
Key Enforcement Areas
- Mis-selling & High-Cost Lending
- Weak affordability assessments.
- Misleading promotions.
- Inadequate arrears and vulnerability monitoring.
- Consumer Duty Compliance
- Boards must evidence good consumer outcomes, not just maintain policies.
- Reporting Failures
- CCR009 and other returns are closely monitored.
- Late, inaccurate, or incomplete submissions may trigger supervisory engagement or enforcement.
- Financial Promotions
- Online adverts, influencer marketing, and comparison sites remain under FCA scrutiny.
Practical Lessons for Firms
- Embed strong data governance.
- Track consumer outcomes with metrics.
- Audit promotions and communications.
- Review operational policies and procedures.
- Document board oversight and decision-making.
How ALPH Legal Can Assist
- Enforcement trend analysis and actionable recommendations.
- Business and operational reviews to identify compliance gaps.
- QA and oversight support on MI, promotions, and consumer outcomes.
- Policy and strategy alignment to meet FCA expectations.
ALPH Legal & Compliance can assist with all aspects of your business’s compliance needs, whether that be compliance structure and policy, internal/external audit, business and regulatory change support, authorisation, supervision or just some general expert advice and guidance!