Previously, I used the group licence, what should I do?

The group consumer credit licence scheme will no longer apply. The replacement regime will use Part XX, Financial Services and Markets Act 2000 (the Act), the same part of the Act that enables CARB to license firms to undertake investment business (DPB licensing).

For the transitional period between 1 April and 30 September 2014, a firm that was eligible to conduct consumer regulated activities under the group licence will be able to conduct the equivalent credit-related regulated activities under the Institute’s Consumer Credit (Transitional Arrangements) Regulations.

When conducting such credit-related regulated activities, the firm must conduct them in the same way as it conducted them under the group licence. See the ‘Guidance for those undertaking consumer credit activities’ in the section on the group licence.

Eligibility will be a firm that is:

• Audit registered under the Audit Regulations;
• Licensed under the DPB Handbook;; or
• A ‘member’ firm, with a definition similar to that used in the Principal Bye-laws.

However, a firm that is also FCA authorised, cannot be eligible under these arrangements.

A firm will only be able to provide a credit-related regulated activity to a client if that activity arises out of, or is complementary to, one or more professional services that are provided to that client. This is known as client incidentality.