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Lending & consumer credit
Lending and consumer credit authorisation
Authorisation for lenders, brokers and consumer-credit firms — permissions, affordability, conduct and collections, under the FCA in the UK and comparable regimes elsewhere.
We authorise consumer and commercial lenders and build the conduct frameworks lending regulation demands — affordability, fair treatment of borrowers, and arrears handling that survives scrutiny when a case reaches the Ombudsman.
Consumer credit is a conduct regime before it is a prudential one. The regulator's central question is not whether you can lend profitably but whether your customers will be treated fairly across the whole lifecycle: how the product is advertised, how affordability is assessed, what happens when someone misses a payment, and how you evidence all of it after the fact. Applications that treat lending policy as a commercial document and compliance as a separate folder tend to attract long question lists.
Who we do this for
- Consumer lenders, including instalment and revolving credit
- Buy-now-pay-later and point-of-sale finance providers
- Motor and asset finance firms
- Bridging, development and specialist property lenders
- SME and commercial lenders inside the regulated perimeter
- Credit brokers, debt purchasers and collections businesses
Full permission, limited permission or appointed representative
Limited permission covers a narrow set of activities — broadly, secondary credit broking and some not-for-profit debt work — and is a materially lighter application. Everything else needs full permission. The appointed representative route puts you under an authorised principal, which is faster and cheaper to start, but the principal owns the permission, sets your risk appetite and can terminate the arrangement. The FCA has tightened its expectations of principals considerably, so AR arrangements now involve more oversight of you than firms often expect.
Where the perimeter actually sits
Lending to a company is generally outside the consumer credit regime, but lending to a sole trader or a small partnership frequently is not — the regulated perimeter follows the borrower, not the branding. Credit broking catches far more introducer arrangements than firms assume, including some referral and comparison models. Getting this analysis wrong is the most expensive mistake in the sector, because it is usually discovered after the lending has started.
Affordability and creditworthiness
The rules require an assessment proportionate to the credit, the borrower and the risk of detriment — not a credit score alone. That means documented income and expenditure treatment, a policy on when you will and will not rely on bureau data, defined tolerances, and evidence that the assessment actually influences lending decisions. Where automated decisioning is used, expect to explain the model, its monitoring and its override process.
Promotions, arrears and the Consumer Duty
Financial promotions must be clear, fair and not misleading, with an approval process and a records trail. Arrears handling requires genuine forbearance options and staff able to identify vulnerability. And the Consumer Duty sits across all of it, requiring evidence of good outcomes and a board-level view of outcomes monitoring — which now forms part of what a new applicant is expected to have designed before launch, not after.
Where we authorise
United Kingdom
Full and limited consumer-credit permissions, and the appointed representative route.
Europe
National lending and credit-intermediary regimes.
Rest of world
Lending and credit licences in major hubs.
How the process runs
Perimeter and permission
Which activities you are performing, whether the borrower type brings you into the regime, and whether full permission, limited permission or an AR arrangement fits the plan.
Building the pack
Regulatory business plan, lending and affordability policy, conduct and vulnerability frameworks, promotions approval process, arrears and forbearance policy, financial model.
Submission and case officer
The statutory deadline is six months for a complete application and twelve for an incomplete one. Consumer credit applications routinely attract detailed questions on affordability methodology.
Getting operational
Decisioning live and monitored, collections staff trained, outcomes monitoring running, and reporting obligations diarised before the first loan is written.
Common questions
How long does FCA consumer credit authorisation take?
Six months for a complete application, twelve for an incomplete one. Full permission applications commonly run six to nine months from submission, and limited permission is materially quicker. Preparation typically adds two to three months.
Do I need authorisation to lend to businesses?
Often not — lending to a limited company is generally unregulated. But lending to sole traders and small partnerships frequently falls inside the consumer credit regime, and the analysis turns on the borrower and the agreement rather than on how the product is marketed. This is worth settling before you lend, not after.
What is the difference between full and limited permission?
Limited permission covers a narrow set of activities, principally secondary credit broking, and involves a lighter application and lower fees. Lending itself, debt collecting, debt administration and mainstream broking all require full permission.
Should I become an appointed representative instead?
It is faster and cheaper to launch, and for some models it is genuinely the right structure. But the principal holds the permission, controls your product and can end the relationship — and following the FCA's tightening of the AR regime, principals now apply significantly more oversight than they once did.
What does the FCA focus on in lending applications?
Affordability methodology and whether it demonstrably drives decisions, the arrears and forbearance approach, financial promotions governance, and whether the firm has designed outcomes monitoring rather than describing it in principle.
More on how we work, fees and timelines is on the FAQ page, and the regimes we cover are set out under jurisdictions.
Why firms use Pitchsd
We have run lending books and the compliance functions that sit over them, and we have defended affordability and forbearance decisions in front of both the regulator and the Financial Ombudsman. That shapes how we write a lending policy: to be operable and defensible, rather than to read well in an application.
We also build the technology the business runs on, so the platform and the permission arrive together rather than being someone else's problem. And we can put senior people into the business — a fractional MLRO, non-executive directors, a CFO — through our network. Get in touch to talk through where your application stands.