FCA Regulatory Business Plan

REGULATORY BUSINESS PLAN – XX SOLUTIONS (HULL) LTD

Background

The applicant firm is:

[XX]

XX Solutions (Hull) Ltd (“XX” or “The firm”) is managed and owned by XX. It was incorporated in January 2010 and provides plumbing, heating and air conditioning services. The Company Registration Number is XX.

The firm does not use, and has never used, any trading names other than its official name.

The firm’s approximate annual turnover is £XX. Mr XX is aiming to grow the business year on year by gaining extra customers via advertising and word-of-mouth, but otherwise does not have any specific growth or expansion plans.

Organisational structure

XX employs just one staff member – Mr XX’s wife, who conducts administration activities. The firm also uses a sub-contractor to carry out plumbing and heating services. These other personnel are exclusively engaged in the company’s core business of providing plumbing, heating and air conditioning services, and will not be involved with the firm’s intended consumer credit activities.

Application to carry out consumer credit activities

Mr XX has identified an opportunity whereby he can increase the firm’s turnover by offering to introduce customers to a firm based in Kirkham, Lancashire called XX Ltd (trading as XX), who are currently listed on the Consumer Credit Interim Permissions Register. For this reason, the firm is making an application to be authorised by the Financial Conduct Authority (FCA).

Customers who are accepted by XX will take out unsecured personal loans for the purposes of paying for plumbing or heating systems. A typical loan may be for £2,000 (up to £6,000 for complex systems), and would be repaid in monthly instalments over a typical term of five to six years.

The expected increase in XX’s turnover from credit activities will be in the region of £10,000 to 15,000 per annum.

XX has no specific target date by which it wishes this application to be approved, and simply intends to commence consumer credit activities once authorisation has been received.

The firm has never been subject to any of the following:

  • Criminal proceedings

  • Civil proccedings

  • Insolvency events

No significant complaints have been made against the firm in the last five years

Compliance arrangements

Mr XX is the only director of XX. He will carry out all necessary roles associated with compliance, such as Compliance Oversight Officer, Complaints Officer and Money Laundering Reporting Officer, and is the only individual from the firm who might require individual approval to carry out a controlled function.

When dealing with a customer who is making a significant purchase, Mr XX will enquire as to whether the customer wishes to purchase on credit. If a customer is interested, he will gather basic personal and contact information only (name, address, telephone number, email address) and pass these details to XX. XX will not ask for any information about a customer’s financial situation.

XX will act as an introducer only. It does not intend to make decisions as to whether a loan is suitable and/or affordable for a particular customer, and will leave these decisions to XX.

XX will also verify the identity of all customers interested in finance, using the procedure outlined in its Anti-Money Laundering Procedure.

All information gathered from customers will be handled according to applicable legislation, and the provisions of the firm’s Data Protection Procedure.

All customer complaints concerning the firm’s consumer credit activities will be handled in accordance with the firm’s Complaints Procedure.

Mr XX acknowledges that his background and experience is in the plumbing and heating industry and not in financial services. However, his involvement in consumer credit activities will be confined to gathering basic personal and contact information from customers and passing these details to another party. He undertakes to undergo basic training in the areas of consumer credit and financial services, and to keep up to date with industry developments via the FCA website.

Sourcing clients

The clients of XX’s consumer credit activities will be the same as its clients for its core business activities. Clients for core business activities will be sourced via:

  • Word of mouth
  • Local newspaper advertising
  • Website advertising (through the firm’s own website and online business directories)

At commencement of authorisation, XX will not have any consumer credit customers, but estimates that it may have between 15 and 20 such customers after 12 months of authorisation.

Marketing arrangements

XX may use some or all of the following methods to market its consumer credit activities:

  • Personal, face-to-face marketing
  • Local newspaper advertising
  • Website advertising (through the firm’s own website and online business directories)

Before making any promotion, the content of the promotion will be checked thoroughly against the FCA’s rules on Financial Promotions in the Consumer Credit sourcebook.

Remuneration

XX will not receive fees or commission payments from customers in respect of its consumer credit activities, and will not receive payments from XX.

Professional advisers

The only professional adviser currently used by XX is the accountant referred to below:

XX

XX Chartered Certified Accountants

129 Beverley Road

Hessle

HU13 9AN

Tel: 01482 649775

The firm’s accounting year end date is January 31 each year.