As part of the Government’s programme of regulatory reform for financial services, the responsibility for regulating consumer credit was transferred from the Office of Fair Trading (OFT) to the Financial Conduct Authority (FCA) on 1 April 2014.
Any Green Deal Provider offering Green Deal Plans, which are regulated consumer credit agreements, will need to hold a valid FCA authorisation (unless it is exempt under section 21 of the CCA). This will need to cover appropriate permissions for carrying out regulated consumer credit activities, given that the Green Deal Provider will be the lender and will be providing credit to the consumers. This is irrespective of whether the Green Deal Provider sources finance from a third party (for example via the Green Deal Finance Company).
The supply chain operating under the Green Deal must also hold appropriate permissions. Under FCA framework both credit broking and credit intermediary are a regulated activity requiring FCA permission. In essence, FCA has two broad categories of authorisation for consumer credit firms: ‘limited permission’ and ‘full permission’. It is the responsibility of each company to ensure that they have the correct permissions for the type of activities they carry out under the Green Deal and within their wider business.
In order to support Green Deal Providers with FCA authorisation process, the Green Deal Oversight and Registration Body (GD ORB) and the Financial Conduct Authority (FCA) hosted a webinar on the application process for FCA permissions required to operate as a Green Deal Provider. The GD ORB and the FCA have developed a Q&A document (ORBCOMM028 – see right) in order to answer the subsequent questions submitted by Green Deal Providers to the GD ORB following the webinar.
Additional information is available at the following resources: