Do credit brokers introducing customers to lenders need FCA authorisation?

Introducing customers to lenders is credit broking under RAO Art.36A even if the firm never lends, so it usually needs FCA authorisation or appointed representative status, unless an exclusion applies.

Limited permission may be available where credit broking is secondary to selling your own goods or services, but the FCA says it is not available to domestic premises suppliers, so firms that sell in customers' homes generally need full permission.

Effecting an introduction to a lender, or presenting or offering credit, is credit broking even if you never lend. Limited permission may be available only if credit is secondary to selling your own goods or services and you do not sell in customers’ homes. It can change depending on the answers to questions such as: Is introducing customers to finance secondary to selling your own goods or services, with most of your revenue coming from those sales? Do you sell or arrange the work in customers’ homes, for example installations? Do you ever lend your own money or keep customers’ agreements on your own book? Do you operate under an authorised broker or network that takes regulatory responsibility for you?

Start with: Credit broking: the activity definition; Perimeter guidance on credit broking (PERG 2.7); FCA: secondary credit brokers; Conduct rules for credit brokers; Pre-contract disclosure including commission. This is an initial view from published FCA material, not an FCA determination.

Map what the customer sees and what you send to the lender, and how you are paid. Decide between full permission, limited permission (if eligible) and appointed representative status. Put CONC 2.5 broker conduct rules and CONC 4 commission disclosure in place. Review financial promotions and complaints handling.