If you're a Full Permission credit broker and you supply a non-financial service, find out if you still hold the correct permission.
We've reviewed our interpretation of the consumer credit legislation[1] for Limited Permission secondary credit brokers. Specifically, how it applies to credit broking firms whose main business activity is the supply of non-financial services.
If you were authorised by us as a Full Permission credit broker firm, you may be eligible to apply to become authorised as a Limited Permission firm instead, depending on what activities you undertake.
Our review doesn't apply to firms that are already authorised as Limited Permission.
Check if you're eligible to apply to change your authorisation
Answer the questions below to see if you can apply to us to change your authorisation from Full Permission to Limited Permission.
These questions are only for Full Permission secondary credit brokers that think they might be impacted by our review. The questions don't represent general guidance about whether your firm should be Limited or Full Permission.
Our page for secondary credit broker applicants[2] has more information about the permissions an authorised firm will need based on the activities it intends to carry out.
Are you currently authorised as a Limited Permission firm?
Are you currently authorised as a Full Permission Credit Broker?
Does your current permission allow you to conduct any regulated activities other than consumer credit activities[3] – for example, insurance distribution or mortgage broking?
Do you meet the definition of a domestic premises supplier?
This is when you sell, offer to sell or agree to sell any of your goods, or offer to supply any services or contracts to supply services, whilst physically present in a customer’s home.
Do you make introductions in respect of consumer hire or hire purchase agreements AND, as part of this, do you engage in debt adjusting and/or debt counselling activities?
Are you a ‘supplier’ of a service that is not a regulated financial activity?
Would you still be credit broking if you stopped supplying that non-financial service?
Does more than 50% of your overall revenue derive from your credit broking activity?
Based on your answers, your firm could potentially be impacted by our review. This means you may be eligible to vary your permission to become a Limited Permission credit broker.
If you want to apply to change your authorisation to Limited Permission, please submit a variation of permission (VoP)[4] application through our Connect[5] system.
Your application must explain:
- your business model, and whether it's changed since you first applied to us for authorisation
- why you believe your firm is broking credit in connection with the supply of services
If, after we've assessed it, your firm is entitled to move from Full Permission to Limited Permission Credit Broking, we'll let you know and issue a part refund where applicable.
Your firm won't be affected by our review. Only firms that currently have Full Permission authorisation are impacted by the changes.
Your firm isn't impacted by our review and your regulatory status won't be affected.
Your firm won't be affected by our review. Firms that carry out other regulated activities will still require Full Permission authorisation.
Your firm is unlikely to be impacted by our review because domestic premises suppliers usually require Full Permission Credit Broking permissions.
Your firm isn't impacted by our review because this combination of activities requires Full Permission authorisation.
Your firm isn't impacted by our review. Firms whose primary business is to carry on a regulated financial activity don't get authorised with Limited Permission – they must have Full Permission authorisation.
Your firm is unlikely to be impacted by our review because the credit broking appears to be independent to the supply of your services.
Your firm isn't impacted by our review. If your revenue from credit broking exceeds that of your unregulated business, we don't consider the credit broking to be ancillary. This means you can't be a Limited Permission firm.
Frequently asked questions
If I apply to change my permission, how long does the process take?
Once we have all the information we need, we'll typically assess an application within 6 months.
However, we aim to determine applications faster than this and you can expect to hear from your case officer throughout the process.
Do I have to pay to change my permission?
No, not in this instance.
Will I need to change my firm’s senior management functions (SMF)?
Yes, if we determine that your firm is eligible to change its permission.
Limited Permission firms have just the one SMF role: SMF29 (Limited Scope Function).
We'll ask you who at your firm is the most appropriate individual to perform this function. If your firm currently has multiple SMFs, you'll need to change this so that there's only one SMF holder.
Will my reporting requirements change?
You should continue to report in line with your scheduled reporting requirements. The reporting period should stay the same, as long as your firm’s Accounting Reference Date (ARD) hasn't changed.
When will the Financial Services Register be updated?
It should reflect the change to your firm’s permission within 48 hours of us approving your VoP application.
When will I receive my refund?
If we determine that you're eligible for a refund, we'll calculate and process it accordingly.
A refund can take up to 3 weeks to process from when we have all the information we need and we've made our decision.
How much will my refund be?
If we agree that you're eligible for a refund, the amount will be unique to each firm. It will depend on how much you paid at the time your authorisation application was submitted, and your yearly consumer credit income which is used to calculate your annual fees.
Any refund due will include the addition of 8% simple interest.
What if my firm is behind with fee payments?
Any refund owed to you will be offset against the amount owed by you in the first instance. Any remaining amount over and above the amount owed will be refunded to your firm.
What if my firm submitted an application for Full Permission Credit Broking instead of Limited Permission Credit Broking, but the application wasn't approved?
In very limited circumstances, some firms that submitted an unsuccessful application for credit broking permissions may be eligible for a partial refund.
This could apply if your firm was told it had submitted the wrong type of application (ie for Limited Permission rather than Full Permission) because of our interpretation at the time.
If we didn't approve a firm's application for other reasons (eg the firm applied to carry on the wrong activities, or couldn't demonstrate that it met our threshold conditions) no refund will be due.
What if I was authorised, but my firm has since cancelled its permission? Will I still get a refund?
If your firm is no longer authorised but you believe you would have been impacted by our review, you may still be eligible for a refund.
You won't need to submit a variation of permission application. Instead, please email us:
If you need more help
If you're still not sure whether you're impacted by our review, you can call us on 0300 500 0597.
We're open Monday, Tuesday, Wednesday and Friday 9am to 5pm, and Thursday 9.45am to 5pm.
