Our Consumer Credit Services

FCA Authorisation

Acquiring FCA authorisation to operate in consumer credit requires robust governance, adequate systems and controls, and adherence to the FCA’s threshold conditions. We guide you through every stage of the application process — from assessing which permissions you’ll need to preparing documentation and financial information.

Our end‑to‑end support includes:

• Determining regulated vs. exempt activities.
• Advising on limited or full permission requirements.
• Preparing regulatory business plans, policies and frameworks.
• Drafting financial forecasts and regulatory submissions.
• Managing FCA queries and post‑authorisation obligations.

Lending Requirements under CONC

Creditworthiness

Ensuring robust and compliant creditworthiness assessments is central to meeting FCA expectations under CONC 5 and the broader responsible lending framework.

• Designing and reviewing creditworthiness and affordability assessment frameworks.
• Assessing income and expenditure methodologies.
• Reviewing the use of credit reference agency data and third‑party information.
• Conducting file reviews to test the effectiveness of lending decisions.
• Gap analysis against CONC responsible lending requirements.
• Strengthening governance and oversight of credit decisioning processes.

Our approach ensures your creditworthiness processes are proportionate, documented and defensible under regulatory scrutiny.

Responsible Lending & Lifecycle Compliance

Consumer Credit compliance does not sit in isolated stages. The FCA expects firms to evidence fair customer outcomes across the full product lifecycle — from product design and financial promotions, through underwriting and sale, to post‑contract servicing and forbearance.

Our support spans this entire customer journey, helping firms embed regulatory expectations into day‑to‑day operations and governance frameworks.

Areas of Supervisory Focus

We focus on the areas currently receiving the greatest FCA scrutiny:

• Price and fair value: assessing product design, fees and charges against the Consumer Duty expectations.
• Commission arrangements: reviewing structures, conflicts of interest and disclosure practices.
• Financial promotions: assessing clarity, accuracy and customer understanding.
• Affordability and eligibility: creditworthiness frameworks, income and expenditure methodologies and decision testing.
• Forbearance and customer support: arrears handling, repeat borrowing, refinancing practices and fair treatment of vulnerable customers.

We help firms demonstrate that responsible lending principles are applied consistently not just at point of approval but throughout the life of the agreement.

Arrears, Default & Forbearance

The fair treatment of customers in financial difficulty remains a key supervisory priority.

• Arrears and forbearance policy development and review
• Alignment with CONC 7 requirements
• Vulnerable customer frameworks
• Collections strategy and communication reviews
• File reviews and thematic assessments
• Remediation programmes where required

We help ensure your approach to arrears management reflects regulatory standards and delivers appropriate customer outcomes.

Financial Promotions & Representative APR

Consumer credit promotions are subject to detailed and prescriptive FCA requirements, particularly in relation to Representative APR and Representative Examples.

• Review and approval of financial promotions
• Guidance on displaying Representative APR and Representative Examples
• Review of customer journeys, including online and digital channels
• Third‑party introducer oversight (where applicable)
• Monitoring frameworks for ongoing promotional compliance

We help firms ensure promotions are clear, fair and not misleading, and aligned with CONC 3 requirements.

Commission Disclosure

The FCA continues to focus on commission arrangements and transparency, particularly within credit broking models.

• Reviewing commission and remuneration structures
• Designing disclosure frameworks in line with regulatory requirements
• Assessing conflicts of interest risks
• Supporting remediation where commission models require review

Our work ensures commission arrangements are transparent, appropriately disclosed and aligned with customer outcome expectations.

Ongoing Compliance Support

Many consumer credit firms require structured, ongoing compliance support beyond project‑based reviews. Our dedicated compliance services provide scalable oversight aligned to FCA expectations.

Learn more about our ongoing compliance services.

• Governance and committee support
• Compliance monitoring and thematic reviews
• Outsourced or co‑sourced compliance resource
• Regulatory reporting and supervisory engagement

Why Consumer Credit Firms Choose Ocorian

Consumer credit firms operate under close regulatory scrutiny. Pricing must demonstrate fair value. Affordability assessments must be robust. Broker and intermediary relationships require clear oversight and accountability.

The FCA’s focus on commission arrangements, financial promotions, repeat borrowing and forbearance means compliance must be embedded throughout the customer journey from product design through to post‑sale servicing.

We support firms in translating these requirements into practical governance frameworks and day‑to‑day processes that align regulatory expectations with commercial delivery.

• Experienced consumer credit specialists
• FCA‑aligned, pragmatic advice
• Lifecycle support - from product design to post‑sale servicing
• Strong governance and oversight expertise
• Commercially focused compliance solutions

Speak to our Consumer Credit Specialists

Whether you're applying for FCA authorisation, preparing for regulatory change, or looking to strengthen your existing compliance framework, Ocorian provides the insight, experience and technology you need to operate with confidence.

Contact us today to discuss your consumer credit requirements.