As far as I can figure it, my business needs a consumer credit licence for three functions. The first is that of advising on equity release mortgages. Currently we do one or two a year, but we expect to do more.
Secondly, we need one for the pro bono debt counselling work we do, because, in my opinion, the MAS is useless, and the CAB is underfunded and overworked. Thirdly, we need a CCL to be able to turn business away by saying to a client: “I recommend that instead of giving me £100k to invest, you actually use it to pay off your mortgage.” We frequently do at the free first meeting we offer prospective clients, because we are honest and we have the client’s best interests at heart, even if it means we earn nothing from some meetings.
When the OFT administered consumer credit licensing the application was a simple form that took me half an hour, at the most, to complete. Now the FCA has got hold of it, it has become the usual gargantuan job-creating, business-preventing, time-and-money-wasting exercise that needs its own jargon-buster, webinars and its own ‘application window’. Once we have figured out how to apply, we understand that it will then take six to 12 months for the FCA to decide whether we should still be allowed to hold a licence.
All this for a firm with no upheld complaints ever, none submitted to Fos ever, no late submissions of the RMAR ever, that has held a CCL since 2006 and which now holds the interim permission after paying the FCA for that privilege, when we had already paid the OFT for a ‘forever’ licence.
For a firm doing what we do, with our record, is this proportionate? Cost/benefit analysis, anyone?
Neil F Liversidge
Managing Director, West Riding Personal Financial Solutions, Castleford, West Yorkshire
