CHALLENGE

  • Our client, an energy provider, required a consumer finance specialist to assist with their application for FCA Consumer Credit permissions. The resource was required on a secondment basis for a period of three months.
  • The specialist was required to provide general compliance guidance and advice on all matters relating to our client’s consumer finance offering (a range of loan products to help customers purchase new boilers and heating equipment).
  • Our client also required us to provide a Compliance Monitoring Manager, who would design and lead a risk-based monitoring programme covering all areas of their residential customer activity, including the consumer finance business as well as insurance backed service and maintenance agreements with retail customers across the UK.
  • We were chosen following our submission of candidate CVs for their role and candidate interviews with the firm’s Head of Compliance.

ACTION

  • One of our specialist consultants was seconded into the Consumer Credit Guidance role. He worked with our client’s Finance Company Senior Leadership Team and their Compliance Team.
  • Our consultant was instrumental in building our client’s Regulatory Business Plan and developing processes and documents associated with the plan.
  • He also acted as the general point of reference for consumer credit queries within the Legal and Compliance function, including writing and delivering consumer finance training, signing off financial promotions, and providing general guidance.
  • We also provided a second specialist consultant to fulfil the Compliance Monitoring Manager role. Our consultant led the Compliance Monitoring Team through a period of transition and internal change, ensuring the timely delivery of monitoring reports and remedial actions as necessary.
  • During the secondment, our consultant also undertook the recruitment and training of new Compliance Monitoring Officers and development of the existing team. This development activity focused on upskilling the team in relation to file checking, call listening, interviewing and report writing.

RESULT

  • The firm’s application for consumer credit permissions was submitted on time and to a high standard – and the firm subsequently received these permissions from the FCA.
  • The compliance monitoring programme was run successfully and helped our client to delivery good outcomes for their customer base.
  • We left our client with Consumer Credit Act training material and had enhanced a number of the firm’s existing processes and procedures by the end of our engagement (relating to sales, monitoring and complaints, as well as other areas). In addition, we wrote and delivered a workshop on consumer finance which forms part of the firm’s training library and which will be used going forwards.
  • As a result of our impact on the client, both secondments were extended beyond the original dates, with both consultants completing over five months in role.