Non-bank Lender Licence Solutions | Non-Bank Lender Licence Application Management| Post-licensing Risk and Compliance Support

We offer a comprehensive set of solutions to help you obtain and maintain a non-bank lender licence, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technological resources
• Your risk appetite
• Your governance structure
• The products that you offer
• Regulated non-bank 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 non-bank lending regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the non-bank lender licensing process, including but not limited to the following aspects:

• Non-bank lender licence Guidance: Advising on a wide range of aspects associated with a non-bank lender 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 non-bank lender licensing conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the non-bank lending regime
• Non-bank Lender 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 Non-Bank Lender Licence Solutions

We can help you apply for the non-bank lender licence or its equivalents in the following jurisdictions:

• Australia: For more information on the non-bank lender 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 Non-Bank Lenders, you can visit our New Zealand (FSP) page.
• United Kingdom: There are a few licensing pathways in the UK. For more information on the non-bank lender licence – FCA Consumer Credit Permission under the Consumer Credit Act 1974, you can visit our UK Consumer Credit Authorisation page. For more information about the Credit Union Licence under the Credit Unions Act 1979, you can visit our Credit Union Authorisation page.
• Singapore: For more information on the non-bank lender licence – Moneylender’s Licence under the Moneylenders Act, you can visit our Singapore Moneylender 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 non-bank lender licence applications tailored to meet the specific needs of the following businesses:

• E-Money Institutions
• Consumer Credit Firms
• Corporate Finance Providers
• Microfinance Institutions
• Real Estate Lenders
• Payday Lenders
• Peer-to-Peer (P2P) Lenders
• Equipment Financing Providers
• Auto Loan Providers
• Instalment Loan Providers
• Factoring Companies

You can find more information about our non-bank lender licence solutions below:

 

Non-Bank Lenders’ Licensing Preparation

Pre-licensing Compliance Assurance

Our non-bank lender licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a non-bank lender licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the non-bank lender licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your non-bank lender 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
• Non-bank Lender Licence Application Plan: We help you establish a roadmap to effectively meet the requirements for your non-bank lender licence

 

 

Non-Bank Lender 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 non-bank lender licensing solution covers:

• Compliance Model Selection: To help you best comply with the non-bank lending 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 non-bank lenders’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Non-Bank Lender Licence and Entering a Regulated Environment

We help businesses transition from an unregulated environment to operating under the non-bank lending regime, helping them meet their obligations as a non-bank lender licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the non-bank lending 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 non-bank lenders’ obligations globally.

 

Non-Bank Lender Licence and Wholesale Markets

Getting an on-bank lender 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 non-bank lending regime
• Operate under an on-bank lender 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 non-bank lending 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 non-bank lending regime)
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
• Data Management Laws and Regulations

 

Non-Bank Lender Licence Application

We assist with your licence application through ongoing engagement in the non-bank lender licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your non-bank lender 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 non-bank lender licence application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Non-Bank 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 Non-Bank Lender Licensing Issues

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

• Remediation Solutions for Non-Bank Lender Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the non-bank lending regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your non-bank lender 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 non-bank lender 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 non-bank lenders. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated Non-Bank Lenders’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the non-bank lending 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 Non-Bank 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 non-bank 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 and Non-Bank Lender Licence Holders

non-bank lender 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 across various areas.

• If your business focuses on consumer credit activities, including personal loans, payday lending, or retail credit, please visit our  Non-Bank Lender's Licensing Solutions page.
• If your business raises funds from the public for lending purposes, please refer to our Finance Company Licence Solutions page.
• If your business focuses on P2P lending, please refer to our P2P Licensing Solutions page.