As seen in the section on Licence Application Support, the Consumer Protection Act 2022 introduces amendments to CBI codes and regulations, and firms are required to comply with these regulations.
Firms providing PCP, consumer hire and indirect credit will be required to be authorised by the Central Bank will need to ensure compliance with CBI minimum competency requirements at the earliest possible opportunity, and with the CBI Consumer Protection Code 2012 by 16 August 2022
Regarding the authorisation, firms that are already operating in the sector will need to submit a completed “Application for Authorisation as a Retail Credit Firm” and a “Declaration Form for availing of Transitional Arrangements as a Retail Credit Firm” to the CBI no later than 16 August 2022.
Where firms complete this authorisation process by this deadline, they may continue operating in the sector until their application for authorisation is decided upon by the CBI.
In terms of regulatory compliance, newly regulated firms should be aware that, from the point of authorisation, they will be subject to, among other regulations, CBI supervision for compliance with conduct of business rules, including the CBI Consumer Protection Code 2012 and CBI minimum competency requirements or Section 149 of the 1995 Act and the requirement to notify the CBI in respect of any new customer charges or increase in any charge previously notified to the CBI.
At Symmetry, we analyse each organisation under the above headings, and we will work with you to explain the results and put in place the appropriate framework to meet the CBI’s expectations.