A ‘tick box’ approach to regulation won’t work when applying for full Financial Conduct Authority (FCA) authorisation.
Instead dealers need to think about the spirit as well as the letter of the rules of the new regulations, one of its managers Francisco Esteves (pictured) will tell delegates at AM’s F&I Compliance Conference in November.
Taking place at Oxford’s Belfry on November 18, the conference, a first for AM, aims to dispel some of the myths surrounding the takeover of responsibility of consumer credit by the FCA.
Esteves will use the opportunity to underline the differences between the FCA and its predecessor, the Office of Fair Trading.
“We want businesses to be forward-looking, really think about what the regulations mean and how they can be implemented in the workplace,” he explained. “It’s not just a question of sending off your cheque and hearing nothing from us for five years until another cheque is due.
“We will be proactively risk assessing every single firm under our remit. If we come across anything we are unsure about, we don’t immediately assume the company is wrong - but we will probe and question. If we are not satisfied with the answers or outcomes, we will then take action.”
The FCA is encouraging companies to consider the entire customer journey and how processes can be perceived by them which could involve a change of approach in order to become compliant.
When applying for full authorisation, a series of online tools are available to help dealers decide the level of authorisation required but Esteves warns companies without the right processes or people in place are unlikely to be authorised.
Esteves will also explain the FCA’s five objectives to enable dealers to gain a deeper understanding of the organisation’s expectations.
> advertising and pre-contractual promotions;
> assessing affordability;
> reasonable forbearance when recovering debt;
> the provision of advice and ensuring it is in the customer’s best interest and not influenced by an incentive for the business or sales executive;
> and whether the business model is appropriate and supported by a culture of ‘doing the right thing’ for customers.
He added: “Being compliant is about doing the right thing for customers and being able to prove this has been delivered in every case. We want businesses to take responsibility for placing the customer’s interest at the heart of a transaction.”