Credit Broking Compliance Consultants

How MEMA Supports Credit Brokers

Comprehensive support for ARs and Principal Firms

How MEMA helps

Broking looks simple and is heavily conditioned: the permission, the disclosures, the commission arrangements and the introducer chain all have to hold together.

1. 1Map the broking modelExactly what you do — introduce, arrange, or something the perimeter treats differently — and the permissions that follow from it.
2. 2Check the chainLenders, introducers and any unregulated parties in the flow are assessed, because responsibility does not stop at your own front door.
3. 3Review the customer journeyDisclosure, commission transparency and the point of sale reviewed against what a customer is entitled to know and when.
4. 4Test the filesA sample of real cases reviewed against the framework — the evidence that the controls operate rather than merely exist.
5. 5Set up monitoringA recurring review programme with management information, so file quality is tracked rather than sampled once.

Understanding the Appointed Representative Model

How the AR framework works for credit broking businesses

Principal Firm Oversight Obligations

FCA requirements for firms managing Appointed Representative networks

Key Credit Broking Compliance Requirements

What the FCA expects, and the evidence behind it.

• Activity scope

  Define introductions, arranging, advising and exclusions.

• Lender relationships

  Evidence due diligence, oversight and remuneration controls.

• Customer outcomes

  Review disclosures, vulnerability and fair treatment.

• Monitoring

  Test files, communications and conduct controls.

Credit Broking Activities

Understanding what credit broking involves and regulatory requirements

What you will need to produce

• Broking permissions and model map
• Lender and introducer due diligence
• Customer journey and disclosure controls
• File review and monitoring programme

The Credit Broking Compliance journey

The route from scoping your permissions to a decision. The FCA's part of it is fixed; the preparation before it is where applications are won or lost.

1. 1Establish your role in the credit chainIntroducing, arranging and presenting are different activities, and the lenders and introducers around you affect what you are responsible for.
   • Confirm which broking activity you carry on
   • Map lenders, introducers and any unregulated party in the flow
   • Weigh direct authorisation against appointed representative status
2. 2Evidence disclosure and oversightBroking comes down to whether the customer is told what they are entitled to know, when, and whether you can show it happened.
   • Build commission disclosure and point-of-sale controls
   • Set up due diligence over lenders and introducers
   • Prepare the file review programme that evidences it
3. 3Submit to FCASubmitted through the FCA's Connect portal with the application fee of £1,130.
   • Complete submission through Connect
   • Application fee paid at submission
   • Case officer assigned by the FCA
4. 4FCA reviewThe statutory determination period is 6–12 months — six months for a complete application, twelve if it is incomplete when submitted.
   • Case officer raises questions on the submission
   • Further information requests answered and evidenced
   • Weak responses, not complexity, are the common cause of delay
5. 5Permission grantedPermission is granted and the firm can carry on the regulated activity, subject to any requirements attached to it.
   • Permission recorded on the Financial Services Register
   • Any limitations or requirements confirmed
   • Reporting and supervision obligations begin

Related FCA Guidance

Deeper reading on the regulatory framework behind credit broking.

Sectors We Support

This service is available for firms across these regulated sectors

• Credit Brokers
• Consumer Credit