All consumer credit authorised firms will have to report to the Financial Conduct Authority (FCA) periodically with various data sets. This is done for the most part through Regdata and the Connect system.
If you are new to being authorised you will need to get a principal user registered to Reg Data, further information is available from the FCA here: www.fca.org.uk/firms/regdata/how-register. If you want us to submit the reports on your behalf, we have to be nominated as such. Instructions for this are available on request or available on the FCA website.
All firms are required to submit an annual attestation to confirm that the details on the financial services register are correct. You must complete this via connect within 60 days of your accounting reference date commonly known as ARD. If you are unsure of when your ARD falls you can check this on companies house, it is the date shown as “next accounts made up to”.
Here at LS Consultancy, we understand that the task of managing and returning these reports can be tricky for the unfamiliar. It’s vital that you get this right as late or incorrect returns come with a penalty of £250.00 and potentially may lead to the imposition of a financial penalty and other disciplinary sanctions.
Your reporting requirements will be quarterly, 6 monthly or annually depending on the nature and size of your business. Please be mindful that returns are required even if there is nothing to report you still need to submit a “Nil-return”.
In this document we look at some of the reporting consumer credit firms need to conduct. Please note that this does vary from firm to firm, dependant on permissions, please get in touch for more information.
Don’t worry we can help: we provide a service that involves notifying you about your reporting schedule, sending alerts 30 days before deadlines. We’re available to assist with any inquiries you may have concerning the returns.
Once you have the necessary data, we can handle the submission of the returns on your behalf. Additionally, we’ll furnish you with an export for your records, along with an explanatory spreadsheet for clarity.
Consumer credit reporting
- CCR007 consumer credit data (limited permission firms): – this is regarding the income from consumer credit activities, please be aware that even if you have not conducted any credit broking activities you are still required to submit a return for the period. It’s used to levy what fees you will need to pay to the FCA each year and ensure that you are using your regulatory permissions.
- REP008 conduct rules reporting (limited and full permissions); – you must report disciplinary action for conduct rule breaches by all non-senior management staff in REP008 (including directors not holding a senior management function). Please note breaches by senior managers must be reported directly to the FCA via connect. The rules do not apply to ancillary staff.
- CCR001 consumer credit data: financial data – this report covers income, assets, liabilities and your balance sheet.
- CCR002 – consumer credit data: volumes – for this data return, companies should fill out each row that corresponds to an activity they are authorised to perform. This return provides the FCA an encompassing view of the dimensions of the consumer credit market and the methods through which revenue is generated within it.
- CCR003 – consumer credit data: lenders – this report must be completed by firms who lend money to their customers. The objective of this reporting is to provide the FCA with insight into the quantity and value of credit agreements initiated or in existence throughout the reporting duration as well as those outstanding at the end of the reporting period. This encompasses the aprs applied to these agreements as well as the extent of arrears associated with them.
- CCR004 consumer credit data: debt management firms – this report needs to be completed by debt management firms. The report is vital to ensure that prudential resources requirements are met as set out in conc 10 of the FCA’s handbook. The minimum capital requirement varies dependant on value of debts under management but will not be lower than £5,000 as this is the minimum.
- CCR005 – consumer credit data: client money and assets – cass debt management firms must complete this return. The purpose of this return is so that the FCA has an understanding of how much client money and assets is being held by cass debt management firms in relation to debt management activity.
- CCR006 – consumer credit data: debt collection – firms carrying out debt collecting (including peer-to-peer platforms) must complete all of this report. For firms without debt collecting permissions it’s likely you will only need to complete the first question to confirm this activity has not been carried out. The purpose of this data item is to give the FCA an understanding of the activities of firms undertaking debt collection, the size of the market, and to identify potential areas where there could be a risk of consumer detriment.
- Complaints return (Disp 1 ANN 1R): – full permission consumer credit firms are also required to complete part B – 35-45 of the complaints return.
- FIN074 economic crime levy: as consumer credit firms are subject to the money laundering regulations 2017, they also need to complete this return. This is to ensure that firms are charged the correct economic levy. The bandings are as follows:
- Small (under £10.2m) = exempt
- Medium (£10.2m-£36m) = £10,000
- Large (£36m-£1bn) = £36,000
- Very large (over £1bn) = £250,000
Information for consumer credit firms new to regulation wanting to apply for authorisation, their business and tasks for regulated firms, can be found here.
- Financial products and services: Consumer credit
- Financial Promotions: CONC Introduction
- Advertising consumer credit
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