The FCA is more than just the OFT with a new name . . .

The FCA is more than just the OFT with a new name . . .

by Martin Gilbert 

Offering credit to your patients used to be so simple. All you needed was a Consumer Credit Licence and that was it. When a patient wanted to spread the cost of the treatment, you forwarded an application to the lender, they sorted out the paperwork, you did the work and you got paid.

Then the credit crunch came along, and in the aftermath it was decreed that the Office of Fair Trading wasn’t the best organisation to supervise consumer credit (think about the unfettered antics of payday lenders and home reversion scheme providers) and responsibility was transferred to the Financial Conduct Authority.

And they are a different animal altogether. They started gently enough, by writing to all CCL holders and telling them that if they wanted to continue to be credit brokers, they just needed to register for Interim Permission.

Then all IP holders were notified of the Allocation Period in which they have to apply for Authorisation. The last ones finish in February 2016. Applying for authorisation (which for most dentists, who just need to act as Secondary Credit Brokers, will be for Limited Permission) is not too difficult, as long as you have the time and understand the terminology (who knew that ‘agreeing to carry on a regulated activity’ was itself a regulated activity, and one which you have to have).

So you complete the online application and pay the fee. The letter arrives (within their 6 month’s SLA) with your Authorisation, your Firm Reference Number and information about your ongoing obligations. You skim through it, and then file it.

But this is only the start of your relationship with the FCA.

Next you get an email telling you that a Return is due. So you phone the FCA Helpline, who tell you that you should have registered for GABRIEL. Which you didn’t bother with, because you hadn’t really read the letter, and the OFT never used to ask you for any returns, so it hadn’t occurred to you that the FCA would. (CCR008 is required quarterly, CCR007 is annual, and there are fines if you miss the deadlines).

Then you get an email telling you that your Periodic Fee is due. So you phone the FCA Helpline, who tell you that you should have registered for online invoicing. And when you do so, and find the invoice, you’ll see that you also have to pay a Money Service Advice Fee and a Financial Service Ombudsman Levy.

So then you think, I can’t be bothered with this, I’m going to cancel my authorisation. So you phone the FCA Helpline, who tell you that you should have registered for CONNECT (not the one you used for your original application, but the one that was mentioned in that letter) to enable you to make any changes to your standing data. And when you do eventually manage to login, you have to find your way through ‘Start a new application’ to get to the cancellation option.

If you’ve got more money than time, there are plenty of firms out there who’ve made a business out of managing the authorisation for you – typically charging £600 to submit your application and £25 a month for ongoing compliance.

Or you could become an Appointed Representative of a specialist such as Chrysalis Finance, who look after the compliance and the reporting, and provide you with a state of the art online portal to process applications simply and easily. So you can not only get on with giving your patients the best treatments, but you also make them affordable for them. 

Martin Gilbert, a chartered accountant,  is a Director of Chrysalis Finance.