Consumer Credit

Key dates

2026-04-22

The CFPB published a final rule amending Regulation B provisions concerning special purpose credit programs, including new restrictions applicable to programs offered or participated in by for-profit organizations.

2026-07-21

The CFPB's Regulation B amendments became effective. For-profit special purpose credit programs offered or participated in on or after this date must comply with the amended requirements, including the prohibition on using race, color, national origin, or sex as a common eligibility criterion.

2026-08-25

The seven agencies rescinded the 2022 interagency statement and OCC Bulletin 2022-3, effective immediately. Creditors should no longer rely on those issuances or related guidance.

Suggested considerations

• Compliance teams may wish to inventory special purpose credit programs, marketing, eligibility criteria, underwriting policies, written plans, and monitoring practices that were developed or supported by the 2022 interagency statement, OCC Bulletin 2022-3, or related guidance.
• Firms should consider reassessing any program that uses race, color, national origin, or sex as a common eligibility criterion, particularly for credit extended on or after July 21, 2026, against 12 CFR 1002.8 as amended.
• For-profit creditors may wish to confirm that each written special purpose credit program plan contains evidence of need, explains why the relevant class would not receive credit under the organization's ordinary creditworthiness standards, and supports any eligibility characteristic used by the program.
• Compliance teams may wish to remove rescinded guidance from policies, procedures, training materials, legal inventories, product governance documents, and examiner-facing materials, while retaining records needed to explain prior program design and implementation.
• Firms should consider reviewing program communications and applicant data practices for potential discrimination or misleading reliance on the rescinded statement, including communications suggesting that protected-class distinctions are broadly authorized.
• Banks and credit unions may wish to brief fair-lending, legal, product, underwriting, marketing, and model-risk stakeholders and document the governance decision regarding whether each program should be amended, suspended, or continued under current law.

What changed

The 2022 interagency statement and OCC Bulletin 2022-3 are rescinded, effective immediately, and creditors are instructed not to rely on those issuances or related guidance. The rescission does not eliminate the statutory or regulatory framework for special purpose credit programs under ECOA and Regulation B, including 12 CFR 1002.8; rather, it clarifies that those programs remain subject to applicable fair-lending prohibitions. The agencies specifically identify the prior version of Regulation B referenced by the 2022 statement as having been amended.

Key dates

2025-09-10

Tricolor and affiliates filed for Chapter 7 bankruptcy and moved toward liquidation.

2025-12-17

The U.S. Attorney’s Office for the Southern District of New York announced criminal charges against Tricolor executives in connection with the alleged fraud.

2026-08-18

The SEC announced the civil enforcement action against Daniel Chu, Jerome Kollar, and Ameryn Seibold in the U.S. District Court for the Southern District of New York.

Suggested considerations

• Firms should consider performing a targeted review of whether the same receivable, loan, vehicle, inventory item, or other asset can be pledged across multiple warehouse facilities, securitizations, lenders, or managed accounts, including through affiliates and special-purpose vehicles.
• Compliance teams may wish to test collateral eligibility and borrowing-base reporting back to source-level records, payment histories, lien and ownership data, servicing systems, and independent third-party evidence rather than relying solely on management certifications.
• Securitization sponsors, underwriters, and investors should consider reviewing controls for detecting loans that are delinquent, charged off, non-paying, fictitious, materially impaired, or otherwise ineligible but reported as current or eligible.
• Firms should consider reconciling loan-level collateral tapes across all funding channels and establishing exception escalation, independent sign-off, segregation of duties, and documented remediation for duplicate identifiers or inconsistent pledging data.
• Finance and compliance functions may wish to assess whether offering documents, investor presentations, lender certificates, and management meetings accurately describe liquidity constraints, funding needs, collateral encumbrances, and portfolio performance.
• Boards and senior-management committees should consider reviewing governance over collateral operations, securitization disclosures, liquidity reporting, related-party or affiliate financing, and controls over executive certifications.
• Investment managers and lenders may wish to incorporate independent collateral verification, borrowing-base audit rights, data-access rights, concentration and duplication analytics, and covenant triggers into new and renewed transactions.
• Firms with relevant exposure should consider preserving records, communications, collateral tapes, system audit trails, certifications, underwriting files, and exception reports in light of parallel SEC and criminal proceedings.

What changed

The publication does not introduce a new rule, threshold, filing requirement, or compliance deadline. It announces an enforcement complaint under the antifraud provisions of the Securities Act of 1933 and Securities Exchange Act of 1934, including alleged control-person liability against Chu and aiding-and-abetting liability against all three defendants. The SEC seeks injunctions, disgorgement with prejudgment interest, civil penalties, and officer-and-director bars against Chu and Kollar.

Key dates

2020-11-13

The High Court disqualified Howard Roland Duckett from acting as a company director for 10 years under section 6 of the Company Directors Disqualification Act 1986.

2020-12-04

The 10-year company-director disqualification took effect and is stated to run until 2030-12-04.

2025-11-20

The FCA identified this date in consumer communications as the point after which payments requested by Beauforce should be reported; the firm was restricted from regulated activities and ordered to stop accepting consumer money.

2026-08-18

The FCA announced the prohibition of Howard Roland Duckett from performing functions in relation to regulated activities.

Suggested considerations

• Compliance teams may wish to review fitness-and-propriety checks for current and prospective senior managers, including searches for director disqualifications, litigation findings, insolvency events, and other adverse information.
• Firms should consider confirming that senior managers have disclosed all matters relevant to their approval and that changes affecting their fitness, propriety, or ability to perform an SMF are escalated and notified to the FCA where required.
• Firms should consider testing compliance with FCA Principle 11, COCON 2.2.4R, and SUP 10C.14.18R in relation to open, cooperative, and timely dealings with the FCA and notification of disqualifications or other relevant changes.
• Boards and compliance functions may wish to assess whether regulatory records, management-accountability maps, company-director registers, and evidence supporting senior-manager attestations are complete, consistent, and independently verifiable.
• Consumer-credit firms should consider reviewing controls over debt-management client payments, client-money safeguarding, communications, and contingency arrangements for transferring customers if permissions are restricted or withdrawn.
• Firms should consider screening current staff and approved persons against the FCA Financial Services Register and relevant Companies House director-disqualification information before appointment and periodically thereafter.
• Compliance teams may wish to use the case in senior-manager and conduct-risk training to reinforce that misleading the FCA or relying on fabricated information can independently support prohibition, even where the underlying misconduct occurred at an unrelated company.

What changed

The FCA made an individual prohibition order under section 56 of the Financial Services and Markets Act 2000 and withdrew Duckett’s approval to perform the SMF3 Executive Director and SMF16 Compliance Oversight functions under section 63 of that Act. This is an enforcement outcome against a specific individual rather than a new generally applicable rule. The underlying conduct included inadequate company records, repeated lies and reliance on fabricated evidence in High Court proceedings, and failure to notify the FCA of a director disqualification.

Key dates

20 March 2026

- The FCA published the statement announcing increased scrutiny of Annex 1 firms and warning that registration applications should be expected to take longer

TBD (ongoing, from the date of publication)

- Annex 1 firms that are not registered should submit a registration application before continuing Annex 1 activity, because the FCA states such firms need to be registered for AML purposes

TBD (ongoing supervisory cycle)

- Around 900 Annex 1 firms are subject to FCA information requests to support supervisory risk assessment and intelligence gathering

Suggested considerations

• Confirm whether any UK business line falls within Annex 1 scope and, if so, verify that the entity is registered with the FCA for AML purposes before continuing the activity.
• Submit a registration application immediately if the firm carries on Annex 1 activity without being registered.
• Reassess the firm’s AML framework at entity level, rather than relying on group-level policies or parent-company controls, and document why the controls are appropriate for the firm’s own risks and operations.
• Replace any generic or off-the-shelf procedures with policies, controls, and procedures tailored to the firm’s actual products, customers, geographies, and delivery model.
• Prepare evidence of MLR compliance for FCA review, including risk assessment logic, governance arrangements, customer due diligence processes, and monitoring controls.

What changed

• - The FCA is closely scrutinising applications to register as an Annex 1 firm, indicating a tougher gateway for new registrations and potentially more refusals or delay where evidence is weak.
• Annex 1 firms must demonstrate compliance with the Money Laundering Regulations, rather than merely assert that controls exist.
• The FCA is warning firms that registration applications will take longer, which affects launch plans, transaction timing, and group structuring decisions.
• The FCA has sent an information request to around 900 Annex 1 firms to better understand their activities, business models, and risks.
• The FCA says it will use this information, together with other intelligence, to identify and disrupt financial crime risks in the sector.

Key dates

2026-06-08

CFPB issued the Statement on Ability To Repay and Immigration Status referenced by the agencies

2026-07-13

FDIC, OCC, and NCUA issued the interagency guidance on lending to individuals not legally authorized to work in the United States

Suggested considerations

• Compliance teams may wish to review underwriting standards to confirm that capacity-to-repay analysis captures employment-authorization-related income instability.
• Firms should consider whether credit policy, risk grading, and portfolio monitoring procedures explicitly address elevated repayment uncertainty for non-work-authorized borrowers.
• Institutions may wish to reassess documentation and verification controls for income, employment, and supporting records in light of the agencies' stated focus on safe-and-sound lending.
• Teams should consider whether fair-lending, TILA, and ECOA controls are aligned with the CFPB's June 8, 2026 statement and the interagency guidance.
• Risk and finance functions may wish to evaluate whether allowance, concentration risk, and credit-loss assumptions need updating where exposure to this borrower segment is material.

What changed

The publication does not create a new lending ban or a new standalone rule. Instead, it restates that institutions should identify, measure, monitor, and control the credit risks associated with borrowers who are not legally authorized to work in the United States through underwriting practices that assess willingness and capacity to repay according to the credit terms. The guidance specifically links this issue to the CFPB's June 8, 2026 Statement on Ability To Repay and Immigration Status and reminds creditors of obligations under the Truth in Lending Act as implemented by Regulation Z,...

Key dates

2026-07-13

OCC, FDIC, and NCUA issued the interagency guidance

2026-06-08

CFPB issued its Statement on Ability To Repay and Immigration Status, referenced by the guidance

Suggested considerations

• Compliance teams may wish to review underwriting standards to confirm that repayment capacity, source of repayment, and overall financial condition are assessed consistently for borrowers whose work authorization is uncertain.
• Firms may wish to test whether account management, credit classification, and allowance methodologies adequately capture elevated credit risk linked to employment authorization uncertainty.
• Institutions may wish to review consumer compliance controls for alignment with TILA, Regulation Z, ECOA, and Regulation B when evaluating applicants affected by immigration or work-authorized status.
• Risk and compliance teams may wish to update portfolio monitoring, concentration analysis, and documentation standards so that the identified credit risk factors are reflected in governance and reporting.
• Community banks may wish to verify that loan policy language and examiner-facing documentation clearly show how these risks are being identified, measured, monitored, and controlled.

What changed

The publication is guidance, not a new rule or statute, and it reinforces existing expectations rather than imposing a new legal prohibition. It states that lending to individuals not legally authorized to work in the United States may present elevated credit risk because their ability to generate income, maintain employment, and remain financially stable may be more uncertain.

Key dates

31 July 2023

– Consumer Duty (Principle 12 and PRIN 2A) applies to all new and existing in‑scope products and services open to new business for retail customers

31 July 2024

– Consumer Duty applies to closed products and services (legacy books), extending the expectations on product design, monitoring and fair value to those products

Suggested considerations

• Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
• Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
• Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
• Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
• Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.

What changed

• - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
• Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
• Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
• Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
• There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.

Key dates

18 November 2025

– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules

5 December 2025 Deadline

– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)

1 May 2026

– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process

31 May 2026

– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme

30 June 2026

– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)

Suggested considerations

• Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
• Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
• Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
• Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
• Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.

What changed

• - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
• During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
• All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
• Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
• Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.

Key dates

26 June 2026

- CBI publishes the warning notice against Loan Empower Solution as an unauthorised retail credit firm and lists the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal unauthorised-firm and scam monitoring procedures to ensure Loan Empower Solution and its identifiers (name, website, address, email, telephone number) are captured in watchlists, fraud rules, and staff guidance.
• Screen recent and ongoing customer transactions and communications for any references to Loan Empower Solution or similar lending scams requesting upfront “loan fees”, and escalate any matches to fraud and compliance teams.
• Update customer-facing communications and website scam warnings to highlight the risk of advance fee fraud in retail credit, referencing the need to check the CBI registers and unauthorised-firms list before engaging with lenders.
• Ensure call centre, branch, and digital support staff are trained to identify and respond to customers approached by unauthorised lenders, including how to advise customers to verify authorisation status on the CBI website and to report suspected scams.
• Incorporate checks against the CBI unauthorised firms search into onboarding, due diligence, and third-party risk management processes for any lending-related partnerships, introducers, or lead generators.

What changed

• - The CBI has added Loan Empower Solution (website: lesolution.eu) to its public list of unauthorised firms and explicitly categorised it as an unauthorised retail credit firm operating without the...
• The CBI has publicly stated that Loan Empower Solution appears to be operating an advance fee fraud model, where upfront payments are requested for credit services that are never provided.
• The CBI has confirmed that the firm is using a purported Irish business address (The Merrion Buildings, 18–20 Merrion Street, Dublin 2, D02 XH98), a non-Irish telephone number, and a specified...
• The firm’s name has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the CBI’s use of its statutory power to publicly identify entities...
• The CBI has directed the public to its unauthorised firms search and financial scams information pages, implicitly reinforcing expectations that firms promote use of these tools in their consumer...

Key dates

TBD

– HM Treasury’s policy statement has been published, but no specific implementation dates for CCA reform or FCA rule changes are given in the FCA response

TBD

– FCA consultation(s) on key elements of the consumer credit framework are announced as forthcoming; exact dates are not yet specified

TBD

– Future milestones such as FCA Policy Statements, Handbook changes and statutory amendments will follow, but no indicative timetable is provided in the FCA response

Suggested considerations

• Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
• Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
• Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
• Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
• Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.

What changed

• - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
• The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
• The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
• The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
• Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...

Key dates

14 April 2026

Publication date of warning notice; Immediate public alert on unauthorised status of Finance Advice Help.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Suggested considerations

• Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
• Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).

What changed

This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Key dates

2026-04-09

FSCA press release on Fusion Guarantees and unregistered insurance business

2026-03-23

Gauteng Division of the High Court delivered the judgment referenced in the press release

Suggested considerations

• Compliance teams may wish to assess whether construction, performance, or surety-style products could be characterised as non-life insurance under the Insurance Act.
• Firms may wish to review whether their current authorisations actually cover guarantee products that assume contingent obligations in exchange for consideration.
• Legal and compliance functions may wish to align product documentation, marketing language, and contractual mechanics with the true regulatory character of the instrument.
• Counterparty due diligence processes may wish to verify whether guarantee issuers are authorised as insurers before acceptance of the instrument.
• Boards and senior management may wish to review governance controls for regulatory classification risk around bespoke guarantee products.

What changed

The High Court granted the FSCA’s counter-application and declared Fusion’s construction guarantees to be non-life insurance policies under the Insurance Act. The court held that issuing those guarantees without insurance authorisation breached section 5(1) of the Insurance Act, and it interdicted Fusion from issuing construction guarantees going forward. The court also declared the guarantees referenced by Elasah to be insurance policies and ordered costs against Fusion and Elasah.

Key dates

1 February 2021

12 December 2023; Period of Buckley's admitted misconduct (diverting payments and misrepresenting qualifications)

25 February 2026

Effective date of the indefinite prohibition on Buckley performing any controlled functions

01 April 2026

Publication date of the CBI press release announcing the Prohibition Notice

Suggested considerations

• Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
• Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
• Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
• Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
• Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.

What changed

This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.

Key dates

6 April 2007

1 November 2024; Scope of agreements eligible for compensation

26 March 2020 Deadline

Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)

2026 (this year)

Millions compensated

30 June 2026

End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress

31 August 2026

End of implementation for 6 April 2007-31 March 2014 loans; lenders then have 3 months to notify complainants and 6 months for eligible non-complainants

Suggested considerations

• Identify all in-scope agreements (2007-2024 with broker commissions); assess eligibility against tightened criteria (e.g., undisclosed DCA/high commission/tie).
• Contact complainants within 3 months post-implementation; eligible non-complainants within 6 months; invite scheme participation (6-month consumer response window).
• Calculate redress per formula (commission-based, capped, with interest); pay promptly, allowing set-off against customer debts where applicable.
• Gather records now (FCA expectation pre-rules); handle exclusions/exceptions with explanations; prepare for FOS challenges on time-bars.
• Brokers: Respond to lender information requests.

What changed

• - Tightened eligibility: Excludes minimal commission agreements (£120 or less pre-1 April 2014; £150 or less post), zero APRs, unused DCAs, and contractual ties where lenders prove visible...
• Two schemes: Separate for 6 April 2007-31 March 2014 and 1 April 2014-1 November 2024 to mitigate legal challenges on pre-2014 powers.
• Compensation adjustments: Reflects higher 2007-2014 losses; capped in ~1/3 cases to avoid over-compensation.
• Streamlined operations: Lenders contact only complainants or eligible non-complainants; no recorded delivery required, cutting delivery costs >40%.
• Scope expansion: Covers DCAs, high commissions, and contractual ties under Consumer Credit Act 1974 ss.140A-C; includes deceased consumers.

Key dates

December 3, 2020

- CSSF Regulation No 20-08 originally published

January 1, 2021

- Regulation and LTV limits became effective for residential real estate credit on Luxembourg territory

May 21, 2024

- CSSF Regulation No 24-04 introduced temporary adjustments to LTV limits

December 30, 2024

- CSSF Regulation No 24-10 extended temporary adjustments

January 7, 2025

- Most recent Technical FAQ version published (prior to March 9, 2026 update)

Suggested considerations

• *For all lenders:
• *Verify LTV compliance calculations for all new residential mortgage originations using the framework specified in the FAQ, ensuring own funds are calculated as actual equity contributions from borrowers
• *Implement dual LTV tracking for borrowers financing new property through sale of existing property, ensuring compliance with both interim and final LTV ratios
• *Document own funds sources carefully, particularly when cash collateral or sale proceeds are used, as these are only permitted for loans with initial LTV below 100%
• *Prepare for June 30, 2025 transition by:

What changed

• The most recent update (March 9, 2026) to the Technical FAQ reflects the regulatory framework established by CSSF Regulation No 20-08 (as modified by Regulation No 24-10).
• First-time buyers: LTV limit of up to 100%
• Other buyers: LTV limit of 90%, implemented via portfolio allowance Buy-to-Let Residential Loans:
• Standard LTV limit of 80%
• Temporary exemption (until June 30, 2025): Lenders may apply LTV ratios up to 95% for up to 10% of annual production Other Residential Real Estate Loans:

Key dates

24 March 2025

- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance

24 March 2026

- CPC 2025 takes effect; existing 2012 Code ceases (12-month implementation period ends)

Until 24 March 2026

- 2012 Code (with addenda) remains in force

Suggested considerations

• Gap analysis: Map current policies/processes against CPC 2025 using CBI's mapping tool; update for new obligations like digital service design, vulnerability screening, fraud measures.
• Policy/system updates: Implement "secure customers’ interests" framework; enhance disclosures (e.g., mortgages, charges, unregulated activities); train staff on conduct standards/vulnerable consumers.
• Governance/risk: Strengthen board oversight, risk management for cyber/fraud/digital risks; distinguish regulated/unregulated activities.
• Testing/monitoring: Develop records/compliance systems; test advertising/bundling; integrate sustainability claims checks.
• Stakeholder engagement: Review CBI guidance/FAQs; prepare for supervision during implementation.

What changed

• The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for...
• Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
• Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective...
• Specific enhancements: Fraud/scam protections; mortgage switching disclosures; greenwashing prevention via clear sustainability claims; expanded consumer definition (e.g., SMEs up to €5m turnover...
• Supporting materials: Guidance on securing interests/vulnerable consumers, mapping tool for legacy codes, redline amendments.

Key dates

October 2025

Consultation on compensation scheme launched

~June 2026 (3 months post

announcement) - End of standard implementation period; lenders notify consumers of redress

~August 2026 (5 months for older agreements) Deadline

Extended implementation deadline

~September 2026 (3 months post

implementation) - Consumers informed of compensation amounts

30 March 2026 (shortly after markets close)

FCA to publish final rules/approach on motor finance redress

Suggested considerations

• Review and prepare systems: Firms must gear up for redress calculations, notifications, and payouts within the 3-5 month implementation window; voluntary early processing encouraged.
• Monitor complaints: Advise customers to complain directly (avoiding CMCs to prevent 30%+ fee losses); process pre-scheme complaints under forthcoming rules.
• Assess provisions: Quantify exposure (e.g., GBP11 billion industry-wide estimate) and update financial reserves, as done by Santander/Lloyds.
• Compliance checks: Ensure communication channels meet fraud safeguards; cease non-compliant practices per FCA interventions.
• Stakeholder engagement: Track the 30 March announcement (confirmed date forthcoming) and respond to any residual consultation feedback.

What changed

• - Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
• Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options...
• Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
• No final decision yet on proceeding, but likely modifications based on over 1,000 consultation responses, including backlash from lenders.

Key dates

2024

FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**

Suggested considerations

• Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
• Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
• Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
• Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).

What changed

No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.

Key dates

Before end of 2026

- Consumers expected to begin receiving compensation under motor finance scheme

End of March 2026

- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales

31 May 2026 Deadline

- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes

Mid

2026 onwards; - Motor finance compensation payments anticipated to commence

Suggested considerations

• *Immediate Operational Priorities (Pre-May 2026):
• *Governance and Accountability
• Appoint senior managers with explicit accountability for complaints handling and redress programmes
• Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
• Document decision-making frameworks for complaint eligibility and dismissal grounds

What changed

The redress system modernization introduces several structural and procedural reforms: Registration Stage for Complaints A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets. Updated Dismissal Grounds The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making. Enhanced Fair and Reasonable Test Guidance Clearer guidance on how the...

Key dates

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 Deadline

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 Deadline

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Suggested considerations

• *Immediate Priorities (Q1 2026):
• *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
• *Redress Calculator Development: Build auditable, validated redress calculators capable of:
• Repricing loans based on proposed APR reductions
• Calculating compensatory interest at BoE base rate + 1%

What changed

• The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
• Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
• Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
• Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
• Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

Key dates

2025

Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward

Ongoing

IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date

Suggested considerations

• Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
• Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
• Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
• Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.

What changed

• - Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
• Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
• Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...

Key dates

24 October 2025 Deadline

- Consultation response deadline for CP13/25

20 February 2026

- Publication date of PS5/26 (final policy)

~20 August 2026 Deadline

- Implementation deadline for SS2/23 CUSO expectations (six months from PS5/26 publication)

Suggested considerations

• Review and update policies: Credit unions must conduct due diligence/risk assessments before any CUSO investment/use; implement conflict of interest policies, especially for non-credit union partnerships.
• Ensure structural safeguards: Limit liability to investment amount; maintain legal/operational separation between credit union and CUSO; monitor aggregate investments ≤7.5% of capital.
• Governance alignment: Decisions must prioritize member benefits per legislative objects; update internal investment rules to comply with amended PRA Rulebook (Credit Unions Part).
• Implementation planning: Within six months, integrate SS2/23 expectations into operations; non-engaging credit unions need no action but should monitor for opportunities.
• Reporting/oversight: Prepare for PRA supervision on CUSO risks; consider CBA updates if significantly impacting mutuals.

What changed

• - Investment permission and cap increase: Credit unions can now invest in CUSOs using own capital, with the cap raised from 5% to 7.5% of total capital across all CUSOs (clarifications added on...
• Expanded CUSO scope: CUSOs can now serve other UK-regulated mutuals (with Part 4A permission) beyond just credit unions; partnerships with non-credit unions permitted as owners, subject to safeguards.
• Supervisory expectations in SS2/23: New chapter requires due diligence, risk analysis, limited liability to investment amount, legal/operational separation, conflict of interest policies, and...
• Other updates: Chapter 17 of SS2/23 amended due to deletion of SS20/15; six-month implementation window for SS2/23 CUSO expectations.

Key dates

7 October 2025

- FCA letter to CMCs on related expectations

Early 2026

- FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)

31 January 2026

- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures

5 February 2026

- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)

End of March 2026

- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)

Suggested considerations

• Engaging clients and other representatives to confirm client wishes and establish single representative.
• Notifying respondent firms promptly of the sole representative.
• Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
• Robust onboarding checks (e.g., confirm no prior representation).
• Entering new agreements only after prior termination and informed consent.

What changed

This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).

Suggested considerations

• Conduct and evidence fair value assessments: Use frameworks considering product nature/benefits, limitations, total lifetime costs (fees/charges), relative to benefits; benchmark internally/externally; segment by consumer groups including vulnerables.
• Review and act on failures: If no fair value, implement mitigations (e.g., price adjustments, process improvements, product withdrawal); evidence processes and implementation.[FCA blog]
• Monitor markets/products ongoing: Assess at firm/market level, including intangible benefits (e.g., scam protection, support channels); prepare for FCA challenges/enforcement.
• Premium finance specific: All firms review offerings; outliers demonstrate workings or improve (e.g., APR reductions).[FCA blog]

What changed

• No new rules are introduced; this reinforces existing Consumer Duty requirements (effective July 2023 for new products, July 2024 for closed books) on fair value as one of four outcomes...
• Firms must demonstrate evidence of fair value, assessing price against benefits, costs, and services delivered.
• Ongoing reviews required throughout product lifecycle, with actions if fair value fails (e.g., improve, withdraw).
• FCA rejects prescriptive interventions like 0% APR in premium finance to avoid market harm, favoring firm-led assessments.[FCA blog]