Not withstanding that the majority of members were unaffected by the proposed requirements of CP23/21, I thought you would be interested to see the comments below from the FCA following protestations from your trade association regarding, inter alia, both the threshold level for inclusion and the timescale for implementation.

Whilst knowing that only around 35 firms were caught by the original requirements, we strongly resisted the proposal on the grounds that it was entirely disproportionate when considered against the consumer credit sector as a whole.

Although delighted that most firms are now falling outside of scope, we are disappointed that 2/3 firms are still caught by the new regulations. We will be seeking to provide as much support and guidance for them as we can, in order to help identify precisely what these firms need to do by the implementation date and the IT implications. Download the FCA latest statement here.