FCA: CP25/16 Quarterly Consultation No. 48 Member Briefing

The FCA has published a consultation paper (CP), CP25/16 Quarterly Consultation. This member briefing is for the consultation on Chapters 2 and 6.

Chapter 2 outlines several amendments to the Supervision manual (SUP)

The FCA outlines their amendment of SUP 6.4.23G and deletion of SUP 6.4.24G to SUP 6.4.26G, retention of SUP 6.4.22G(5) and (6), and amendment of SUP 6.4.22G.

What does this mean for credit unions?

Amendment of SUP 6.4.23G: If a credit union is deauthorised, it can still be held accountable for misconduct that happened when it was authorised. The FCA will have powers to take disciplinary action against previously authorised firms.

Deletion of SUP 6.4.24G: the powers stated in SUP 6.4.24G are to be transferred to SUP 6.4.23G so that enforcement can be applied to credit unions even after authorisation has been cancelled and they are no longer regulated.

Deletion of SUP 6.4.25G: As enforcement powers can be exercised against a credit union that was formerly authorised, this no longer applies.

Retention of SUP 6.4.22G(5) and (6): If a credit union is being investigated, or there is ongoing enforcement action, the FCA may decide to keep the credit union’s authorisation to make sure the investigation or enforcement action can be completed. Furthermore, the FCA may keep a firm authorised if an investigation is planned to take place.

Amendment of SUP 6.4.22G (references to PRA): The FCA will be the regulator who is referenced in SUP 6.4.22G, the FCA has proposed to remove references to the ”relevant regulator” and the PRA. This is for FCA-authorised firms only and won’t impact credit unions.

Relevant to credit unions with limited permission for consumer credit activities

Chapter 6 outlines amendments to the Supervision manual 16 (SUP 16) on the scheduling of Consumer Credit data returns

The FCA in Policy Statement (PS) 25/3 confirmed the introduction of a new CCR009 return.

As part of a wider review of consumer credit data and consultation on the new CCR009 return, it is proposed that firms with limited consumer credit activities will report data around the calendar year instead of the accounting reference date. The FCA aims to better align with how firms collect and report internally. Credit unions that engage in limited permission consumer credit activities will need to adjust their reporting schedules to a new calendar year format.

This change won’t impact any submission in 2025. The changes will come into force from 1 January 2026

As part of a wider review of consumer credit data, CCR002, CCR003, CCR006, and CCR007 are expected to be turned off after the anticipation of another return, which will cover lending, consumer hire, debt collection and debt administration. Changes will aim to remove any dual reporting requirements.

There are a number of questions within the full consultation, ABCUL have pulled out a number of these that we would like to hear your views on.

Question 2.1: Do you agree with our changes proposed to SUP 6.4?

Question 6.1: Do you agree with the proposal to amend the scheduling requirements for CCR007 to align with the calendar year?

Question 6.2: Do you agree that this change should only be for limited permission firms submitting CCR007? If not, what do you think the scope of the change should be?

Question 6.3: What do you expect the impact of these changes on your firm to be?

Response and Next Steps

ABCUL is eager to hear our member credit unions views on the proposals and ask that all responses be sent to advocacy@abcul.org and received by the close of business on Friday , 11 July 2025