The FCA’s Regulatory Guide for Credit Brokers: A Section-by-Section Compliance Playbook

Credit broking is one of the most heavily populated corners of the FCA’s register — tens of thousands of firms, from motor dealers and retailers offering point-of-sale finance to standalone brokers arranging loans. Most are small. Many treat regulation as something to survive once a year rather than evidence every day.

The FCA knows this, which is why it published a plain-English Regulatory guide for credit brokers aimed squarely at smaller firms. It walks through eight areas, from getting your permissions right to how the FCA supervises firms.

One theme recurs in almost every one of them: the Consumer Duty (PRIN 2A). The FCA comes back to it constantly — in how you advertise credit, how you explain it, how you treat vulnerable customers, and how you evidence the outcomes they actually receive. Treat it as the spine of the guide, not a separate chapter.

This article takes each section in turn: what the FCA expects, and how Fenchurch One helps you meet the obligation and prove it. It is a practitioner’s read of the guide, not legal advice — rule references (CONC, SYSC, DISP, SUP, PRIN 2A) are there so you can go to the source.

1. Running your credit broking business: the basics

What the FCA expects. Credit broking is a regulated activity under article 36A of the Regulated Activities Order. You cannot carry it on unless you are FCA authorised with the right permission — or an appointed representative of a principal who is. The FCA distinguishes limited permission brokers, where broking is secondary to your main business (a retailer arranging finance, say), from full permission brokers, where it is the main event. Your permission must match what you actually do. You must also meet the Threshold Conditions (COND) on an ongoing basis, comply with the Principles for Businesses including the Consumer Duty (PRIN 2A), and keep your authorisation and fees current.

How Fenchurch One helps. Fenchurch One does not apply for your authorisation for you — but once you are authorised, it holds your permissions, records, attestations and returns in one place and keeps them evidenced. The register suite records your permissions and firm details; the FCA attestations turn each ongoing obligation into a tracked, Handbook-mapped record; and the compliance calendar and dashboard keep every recurring task visible — on track, needs attention or overdue.

2. Promoting your business and finding customers

What the FCA expects. Every financial promotion must be clear, fair and not misleading (CONC 3.3). If you quote an interest rate or any amount relating to the cost of credit, you must show a representative example with the representative APR given no less prominence (CONC 3.5). And you are responsible for promotions made on your behalf — by lead generators, affiliates and introducers, across every channel including social media (the FCA’s FG24/1 guidance applies). You need a documented sign-off process and you must keep records of what you approved and when. The Consumer Duty’s consumer-understanding outcome (PRIN 2A.5) sits on top: communications must equip customers to make good decisions.

How Fenchurch One helps. Documents gives you 74 expert-drafted policy templates, including a financial promotions policy — approval process, social-media standards, affiliate oversight — to adopt and adapt, and you can upload your own approved promotions alongside them, each retained and dated, so when a supervisor asks what you signed off and when, the answer is one search away. The 74-chapter Compliance Monitoring Plan library covers what the regulator expects on financial promotions and how to implement it, so your reviews are planned and evidenced rather than ad hoc. And because PRIN 2A.5 makes clear communication a measurable outcome, Fenchurch One’s Consumer Duty attestations record that your promotions actually helped customers decide, not just that they were approved — with the evidence drawn into the AI Compliance Report.

3. Dealing with customers

What the FCA expects. You must act honestly, fairly and professionally in your customers’ interests (CONC 2). Before a credit agreement is entered into, give adequate explanations and pre-contract information so the customer can judge whether it suits them (CONC 4.2). Any fee you charge the customer must be disclosed and agreed in writing, in good time (CONC 4.4). You must disclose the existence — and where relevant the nature — of any commission that could affect your impartiality (CONC 4.5), an area under intense FCA scrutiny since the motor-finance commission reviews. Over all of it sits the Consumer Duty: deliver good outcomes on products and services, price and value, consumer understanding and consumer support (PRIN 2A.3–2A.6), act in good faith, avoid foreseeable harm, and take particular care with vulnerable customers (FG21/1). And it does not stop at the point of sale: you must monitor the outcomes your customers actually receive and report them to your board every year (PRIN 2A.8).

How Fenchurch One helps. Fenchurch One’s Consumer Duty attestations work through PRIN 2A as records: the four outcomes, fair value, vulnerable-customer consideration and a board-challenge trail, each mapped to the Handbook and teaching as it records. The AI Compliance Report draws them together, and the Executive Summary condenses them into a one-page board briefing. Documents covers the surrounding policies — commission disclosure, conflicts of interest, fees and vulnerability — from the 74 expert-drafted policy templates. And the 74-chapter Compliance Monitoring Plan library provides the CONC conduct reviews to test it all in practice.

4. Making sure the right people are in the right roles

What the FCA expects. The Senior Managers and Certification Regime applies to credit brokers (most are limited-scope or core firms). Senior managers need FCA approval and a Statement of Responsibilities; certification staff must be assessed as fit and proper at least annually (FIT); and the Conduct Rules (COCON) reach almost everyone in the firm, with training to match. Staff who deal with customers must be competent (SYSC 5 and the training-and-competence rules), and your Directory submissions must be kept up to date.

How Fenchurch One helps. People makes every person a compliance record, with SM&CR, APER and IDD built in: Statements of Responsibilities, annual fit-and-proper questionnaires, conduct-rules adherence and due-diligence capture. Every appointment and annual attestation leaves an evidenced trail, and there is no limit on the number of people records on any plan.

5. What checks your business needs to have in place

What the FCA expects. You must establish and maintain systems and controls proportionate to your size, including a compliance monitoring programme that actually runs (SYSC 6.1), with clear senior-management responsibility for oversight. You need to manage conflicts of interest, guard against financial crime and fraud — some brokers fall within the Money Laundering Regulations 2017, and all sit under the Proceeds of Crime Act and the failure-to-prevent-fraud offence introduced by ECCTA 2023 — and keep adequate records to demonstrate compliance.

How Fenchurch One helps. The 74-chapter Compliance Monitoring Plan library turns SYSC 6.1 from an aspiration into a schedule: it covers what the regulator expects across the compliance waterfront and how to implement it, and the compliance calendar keeps every review planned, dated and evidenced rather than ad hoc. Fenchurch One’s registers capture conflicts, breaches and the other risks you have to track — each entry dated, owned and evidenced. Where financial-crime risk applies, Fenchurch One’s financial-crime attestations and registers hold the AML, sanctions and fraud controls, each mapped to the Handbook and the relevant legislation. And the dashboard ties it together — on track, needs attention or overdue — with an audit trail behind every record.

6. Handling complaints when things go wrong

What the FCA expects. You need a written complaints-handling procedure that customers can find and use (DISP 1). Complaints must be investigated fairly and answered with a final response within eight weeks — or a summary resolution communication if you resolve within three business days. Eligible complainants must be told of their right to refer the matter to the Financial Ombudsman Service. You should carry out root-cause analysis, feed the lessons back into the business, and report your complaints data to the FCA (publishing it too if you cross the reporting threshold).

How Fenchurch One helps. The register suite gives you a ready-made complaints register — every entry dated, owned and evidenced — so each complaint is tracked against the eight-week clock. The 74-chapter Compliance Monitoring Plan library covers DISP complaints-handling so you can test the process itself. And complaints data and root-cause analysis flow into the dashboard and into the AI Compliance Report — turning individual grievances into the outcome data the FCA expects to see.

7. Updating us

What the FCA expects. Keep the FCA informed. Submit your regulatory returns accurately and on time through RegData (consumer-credit firms file the CCR returns); notify the regulator promptly of significant events and breaches under SUP 15, since Principle 11 requires you to be open and cooperative; and seek approval for any change in control (SUP 11). Keep your standing data and Directory current, vary your permission when your activities change, and pay your fees.

How Fenchurch One helps. Your boards and registers hold your standing data, permissions and firm records as a single source of truth, so what you report matches what you do. The FCA Returns tracker keeps every RegData return deadline in view, with templates for the CCR returns, and the compliance calendar schedules each reporting and notification deadline as a recurring task with email reminders — so a return or a SUP 15 notification is never missed.

8. How the FCA supervises firms

What the FCA expects. Supervision is proportionate to your size, but it is increasingly data-led. Expect information requests, surveys and thematic reviews, with the agenda set by the FCA’s consumer-finance priorities — affordability, fair value, the treatment of customers in financial difficulty, and commission. The common thread is that you must be able to evidence your compliance quickly, not reconstruct it after the request lands.

How Fenchurch One helps. This is what Fenchurch One is for. The dashboard gives you a real-time, RAG-scored picture of compliance health — on track, needs attention or overdue. Because consumer-finance supervision is Consumer Duty-led, your Consumer Duty attestations and their board report are usually the first evidence a supervisor asks to see. Documents keeps your policies and evidence in one place, and the downloadable FCA proof pack exports a dated, referenced record for the supervisor. AI reports turn your live records into board-ready summaries drawing only on what your firm has actually recorded — nothing invented, nothing generic — and every record carries an audit trail. When the FCA asks, you answer in minutes, not weeks.

The FCA’s guide is, in effect, a map of everything a credit broker has to get right. None of it is optional — but none of it has to live in scattered spreadsheets and a once-a-year consultant visit either. Structure each obligation, capture the evidence as you go, and the day the FCA calls becomes a five-minute job instead of a five-day scramble. That is the whole idea behind Fenchurch One.