CONC TP 7A Transitional provisions in relation to the Consumer Credit (Earlier Intervention and Persistent Debt) Instrument 2018

7A.1

CONC 6.7.2R, CONC 6.7.3AR to CONC 6.7.3DR, and CONC 6.7.27R to CONC 6.7.40G

R

A firm may comply with CONC as if the changes made by the Consumer Credit (Earlier Intervention and Persistent Debt) Instrument 2018 had not been made until (but not including) 1 September 2018. But where a firm elects, in relation to a credit card agreement, to comply before that date with CONC as amended by that Instrument, it must comply with the relevant provisions in full. Consequently, the time periods set out in the rules to which this transitional provision applies are to be determined by reference to the date on which the firm first acted in compliance (or purported compliance) with those rules.

1 March 2018 to 31 August 2018

1 March 2018

7A.2

CONC 6.7.27R to CONC 6.7.40G

G

The effect of TP 7A.1 is that no later than 1 September 2018 firms must start to look back at credit card customers’ repayment records over the preceding 18-month period and identify any customers that fall within the application of CONC 6.7.27R (and must thereafter continue to do so on at least a monthly basis). Firms must then send those customers a communication in accordance with CONC 6.7.27R(3). Between 9 and 10 months after this communication is required to be sent, CONC 6.7.29R requires firms to take the additional steps set out in that rule with respect to that group of customers. 18 months after this CONC 6.7.27R communication is required to be sent, CONC 6.7.30R to CONC 6.7.40G potentially require the firm to take the further steps described in those rules in relation to that group of customers where CONC 6.7.30R applies. CONC 6.7.30R applies only where the amount that customer has paid to the firm towards the credit card balance, over the 18-month period following the date on which the CONC 6.7.27R communication was triggered, comprises a lower amount in principal than in interest, fees and charges. This means that the earliest date on which a firm may have obligations under CONC 6.7.30R is 1 March 2020 (except as mentioned below). However, firms are not required to delay implementation to the end of the six-month period set out in TP 7A.1: where a firm takes a step in compliance with one of the rules in question before 1 September 2018 in relation to a particular credit card agreement (for example, carrying out the 18-month review), the time for taking all subsequent steps required to be taken under those rules is to be determined by reference to the date of that first step, and not by reference to 1 September 2018 (or some later date).

1 March 2018 to 31 August 2018

1 March 2018