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CONC TP 7B Transitional provisions in relation to the Consumer Credit (High-Cost Credit) Instrument 2018

1(1)

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(3)

(4)

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Material to which the transitional provision applies

Transitional provision

Transitional provision: dates in force

Handbook provision: coming into force

Handbook provision: coming into force

CONC 6.7.1(4)R, CONC 6.7.3AR to CONC 6.7.3DG, 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 (High-Cost Credit) Instrument 2018 had not been made until (but not including) 19 June 2019. But where a firm elects, in relation to retail revolving credit, 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.

19 December 2018 to 18 June 2019

19 December 2018

7B.2

CONC 6.27R to CONC 6.40G

G

The effect of TP 7B.1 is that no later than 19 June 2019 firms must start to look back at the repayment records for retail revolving credit customers 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 7.7.29R requires firms to take the additional steps set out in that rule with respect to that group of customers. 18 months after the 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 balance on the retail revolving credit account, over the 18-month period following the date on which the CONC 6.7.27R communicated 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 19 December 2020 (except as mentioned below). However, firms are not required to delay implementation to the end of the 6-month period set out in TP 7B.1: where a firm takes a step in compliance with one of the rules in question before 19 June 2019 in relation to a particular retail revolving credit agreement (for example, carrying out the 18-month review), the time for taking 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 19 June 2019 (or some later date).

19 December 2018 to 18 June 2019

19 December 2018