Emma RadmoreFCA is returning to some regular business and has published a short quarterly consultation, proposing changes to:
- clarify FSCS’s power to declare in default firms and successors subject to the proposed new moratorium under the Insolvency Act 1986, with comments due by 5 July;
- changes to CONC 7 consequential on the BBLS. Changes to the RAO have already been made to exempt certain lending through the BBLS that would otherwise have constituted regulated credit agreements. But where lenders take steps to procure the payment of debt under these agreements that is regulated debt collecting. FCA believes firms lending through the BBLS are likely already to have books in relation to which they are required to comply with CONC 7, so they should already have in place appropriate policies and procedures, and so compliance, and the cost of it, with CONC 7 in relation to these loans should not be onerous. Comments on this are also due by 5 July; and
- changes to the OBPAS Sourcebook in relation to criminality checks under MLD5, with comments due by 31 July.
