A FTSE250 Company Secretary writes...
In one small area of our business (amounting to less than 1% of our Group turnover) we are caught by the Consumer Credit Act and are required to hold a Consumer Credit Licence. Since the responsibility for consumer credit passed from the OFT to the FCA we have been operating under an interim licence and had to apply for the full consumer credit licence in June 2015. The process has been arduous to say the least and the FCA are now requesting additional information, namely that we complete an Approved Person application for each of our parent company directors (the Company applying for the licence). The information required to complete the form includes previous address history for three years, employment records for five years (name of employer, nature of business, responsibilities of role), biographical information and a Fitness Propriety questionnaire running to seven pages. We have already completed the Approved Person form for our Chief Executive and believe that the submission of these forms for our remaining executive directors plus our non-executive directors is excessive given that our application should be fairly straightforward.
We would be interested to hear your experiences of dealing with the FCA and Consumer Credit Licence applications and whether you have been able to push back on the request for such detailed information, particularly regarding non-executive directors.
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