Key Takeaways for Consumer Credit Firms
FCA enforcement data from 2025 highlights the importance of proactive compliance, with a focus on consumer harm, financial promotions, reporting failures, and governance weaknesses.
Key Enforcement Trends
- Mis-selling & High-Cost Credit – Inadequate affordability checks, misleading promotions, weak arrears monitoring.
- Consumer Duty Non-Compliance – Policies without evidence of good outcomes; boards must demonstrate oversight.
- Reporting Failures – CCR009 and CRR submissions; late or inaccurate returns trigger supervision or enforcement.
- Financial Promotions & Marketing – Online adverts, influencer marketing, comparison sites are under scrutiny.
Practical Lessons for Firms
- Embed strong data governance.
- Track consumer outcomes.
- Audit financial promotions.
- Review policies and procedures.
- Board oversight and accountability.
How ALPH Legal Can Assist
- Enforcement trend analysis.
- Business and operational reviews.
- QA and oversight support.
- Policy and strategy alignment.
ALPH Legal & Compliance can assist with all aspects of your business’ 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!
Take action now with ALPH Legal & Compliance services!