Consumer credit compliance requires more than checking whether a firm holds the correct FCA permission. A sound review tests the full customer journey, from advertising and affordability assessments to contract terms, arrears support, complaints and record keeping. Harper James is a UK full-service commercial law firm advising businesses on the laws of England and Wales.
Start by mapping every activity that involves credit, hire, broking, debt administration or financial promotion. Confirm the firm’s FCA permissions, appointed representative arrangements and responsible owners for regulated processes. Check that promotions are clear, fair and not misleading, with representative examples, risk information and eligibility conditions presented accurately. Review customer agreements against the Consumer Credit Act 1974, its regulations and the FCA Consumer Credit sourcebook, CONC.
Review the evidence supporting affordability and creditworthiness decisions. The file should show the information collected, the decision made and the reason for any exception. Test whether vulnerable customers receive appropriate support, whether fees and charges are explained before commitment, and whether customers can understand the consequences of missed payments. The FCA’s Consumer Duty places continuing focus on good outcomes, including product suitability, clear communications, fair value and effective customer support. Use this consumer credit compliance resource to structure a wider review of policies, controls and evidence.
Inspect arrears and forbearance procedures, collections scripts, third-party arrangements and complaint handling. Confirm that staff training reflects current policies and that quality assurance reviews actual customer interactions rather than relying only on written procedures. Reconcile customer data, reporting and retention practices with UK GDPR requirements. Keep a central register of permissions, policies, training, monitoring results, remedial actions and senior-management decisions.
End the review with a risk-ranked action plan. Each action should have an owner, deadline, evidence requirement and escalation route. Prioritise customer harm, inaccurate financial promotions, affordability gaps and failures in complaint handling. Maintain a horizon-scanning log for FCA publications, enforcement themes and proposed changes to the Consumer Credit Act framework. Reperform the checklist after material product, system, outsourcing or pricing changes, rather than treating compliance as a one-off exercise.