Consumer Lending Licence Solutions | Pre-licensing Assessment | Consumer Lending Licence Application Management | Post-licensing Compliance Solutions

We offer a comprehensive set of solutions to help you obtain and maintain a consumer lending licence, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• regulated consumer lenders' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the consumer lenders’ licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the consumer lenders’ licensing process, including but not limited to the following aspects:

• Consumer Lending Licence Guidance: Advising on a wide range of aspects associated with the consumer lending licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the consumer lenders’ licensing conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the consumer lenders’ licensing regime
• Consumer Lending Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Jurisdictional Coverage of our Consumer Lending Licence Solutions

We can help you apply for the consumer lending licence or its equivalents in the following jurisdictions:

• Australia: For more information on the consumer lending licence – Australian Credit Licence (ACL) under the National Consumer Credit Protection Act 2009, you can visit our Australian Credit Licence page.
• New Zealand: For more information on the finance company licence equivalent– Financial Service Provider (FSP) Registration for Credit Providers and Consumer Lenders, you can visit our New Zealand FSP Registration page.
• United Kingdom: There are a few licensing pathways in the UK. For more information on the consumer lending licence, visit our:

• UK Building Society Authorisation Solutions page
• FCA Consumer Credit Authorisation page
• UK Credit Union licence page

• Singapore: For more information on the consumer lending licence – Moneylender’s Licence under the Moneylenders Act, you can visit our Singapore Moneylenders Licence page.
• Offshore Jurisdictions:

• Cayman Islands
• British Virgin Islands (BVI)
• Bermuda
• Isle of Man
• Jersey
• Guernsey
• Mauritius
• Bahamas

 

Service Coverage

We offer comprehensive support for a wide range of consumer lending licence applications tailored to meet the specific needs of the following businesses:

• Personal Loan Providers
• Credit Card Issuers
• Payday Loan Companies
• Auto Financing Companies
• Instalment Loan Providers
• Retail Credit Firms
• Microfinance Institutions

You can find more information about our consumer lending licence solutions below:

 

Consumer Lenders’ Licensing Preparation

Pre-licensing Compliance Assurance

Our consumer lending licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a consumer lending licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the consumer lenders’ licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your consumer lending licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Consumer Lending Licence Application Plan: We help you establish a roadmap to effectively meet the requirements for your consumer lending licence

 

 

 

 

Consumer Lending Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our consumer lenders’ licensing solution covers:

• Compliance Model Selection: To help you best comply with the consumer lenders’ licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for deposit takes and lenders and other applicable regulated consumer lenders’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Consumer Lending Licence and Entering Regulated Environment

We help businesses transition from an unregulated environment to operating under the consumer lenders’ licensing regime, helping them meet their obligations as a consumer lending licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the consumer lenders’ licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing consumer lending providers operating in unregulated markets
• Regulated consumer lending businesses that expand into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated deposit-taking or lending services, trading as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with regulated consumer lenders’ obligations globally.

 

Consumer Lending Licence and Wholesale Markets

Getting a consumer lending licence may not always be the best fit for all. For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist consumer lending providers that:

• Operate in the wholesale markets
• Operate under exemptions from the consumer lenders’ licensing regime
• Operate under a consumer lending licence limited to sophisticated, eligible, and wholesale investors

We help these businesses comply with the regulatory compliance obligations that still apply despite the absence of the consumer lenders’ licensing regime or apply under the wholesale-only licensing framework, including:

• Advertisement Rules
• Fair Dealing Regulations
• Risk Management
• Outsourced Providers' Oversight
• Restrictions on offering services to retail investors (an integral part of the consumer lenders’ licensing regime)
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
• Data Management Laws and Regulations

 

Consumer Lending Licence Application

We assist with your licence application through ongoing engagement in the consumer lenders’ licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your consumer lending licence application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Consumer Lenders’ Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving Consumer Lending Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our consumer lending licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for Consumer Lending Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the consumer lenders’ licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your consumer lending licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.

• Licensing Issues Handling: We address common licensing issues encountered during the consumer lenders’ licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for licensed consumer lenders. Our services include, but are not limited to:

 

Ongoing Risk and Regulatory Compliance

• Regulated Consumer Lenders’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the consumer lenders’ licensing regime and other regulatory compliance obligations. You can visit our Compliance Consultancy Service page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for Consumer Lenders.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:
• Regulated consumer lenders’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• AML/CFT obligations for consumer lending and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for consumer lending businesses. For more information, visit our Specialised AML/CFT Solutions page for Finance Companies.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for Consumer Lending Licence Holders

Consumer lending licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in the different areas. The list below is not exhaustive:

Consumer Lending Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil regulated consumer lenders’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can draft and implement policies to reflect consumer protection laws, responsible lending requirements, and hardship protocols.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the consumer lending licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Automated Lending and Credit Decisioning: We assist in implementing compliant systems for automated lending, credit scoring, and associated reporting.
• Consumer Credit Obligations: We can help ensure your lending controls align with responsible lending obligations, interest rate caps, disclosure requirements, hardship assistance, and collections practices.
• Digital Lending and Credit Platforms: We support consumer lenders in meeting obligations for digital and embedded lending services, including eKYC, consent, and digital contract enforceability.

 

Consumer Lending Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with consumer lenders’ licensing obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with regulated consumer lenders’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with regulated consumer lenders’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet regulated consumer lenders’ obligations for operational resilience, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the consumer lending licensing regime.

 

Consumer Lending Licence and Market Integrity/Transparency Requirements

• Standards for Market Conduct: We can help you implement controls for regulated consumer lenders’ obligations to maintain fair and transparent market conduct, including preventing manipulation and insider trading.
• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with consumer lenders’ licensing standards for conduct and disclosure.
• Product Suitability and Governance: We can establish tailored controls to help licensed consumer lenders comply with product suitability and governance obligations, including risk management and governance arrangements across the product life cycle.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

Consumer Lending Licence and Resource Management Obligations

We can help you comply with the following requirements of the consumer lending licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, deposit taking or lending regulations.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

Consumer Lending Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Consumer lenders’ licensing obligations
  • Consumer lenders’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
  • Regulated consumer lenders’ obligations under financial market conduct regulations
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the consumer lending licensing regime, applicable operational standards, and more.