Information on collateral UK Ltd - July 2024

On 1 April 2014, responsibility for regulation of consumer credit and related activities was transferred from the Office of Fair Trading (OFT) to the FCA. Any person (including a firm) who held a Consumer Credit Licence immediately before 1 April 2014, on notifying the FCA of certain required information and paying any relevant fee before 1 April 2014, was granted ‘interim permission’ to carry on consumer credit activities.

Firms carrying on consumer credit activities under an interim permission and wishing to continue to do so after the transition period were required (before 31 March 2016) to apply to the FCA for full authorisation. Firms with interim permission appeared on the Interim Permission Register (‘IP Register’).

On 1 April 2014, Regal Pawnbrokers Ltd was granted interim permission under the reference number 656714. On 12 November 2015, the IP Register was amended by one of the Collateral directors, Peter Currie, so that the name of the firm holding interim permission reference number 656714 read ‘Collateral (UK) Ltd’ (‘Collateral’). The change of company name on the IP Register was not a legitimate means to transfer the interim permission from Regal Pawnbrokers Ltd to Collateral.

On 23 March 2016, an application for authorisation was made by Collateral. It was actively considered by the FCA from April 2016 onwards. On 23 November 2017, during the review of Collateral’s application, it was identified that Collateral was not the holder of a valid interim permission.

Between 23 November 2017 and 29 January 2018 (when the FCA took action against Collateral and amended the Interim Permission Register), the FCA had been engaging with internal stakeholders to establish the action that should be taken.

Additionally, the FCA was engaging with the firm for the purpose of informing its customers that it was not authorised by the FCA and instigating a controlled wind down of the loan book. The FCA did not immediately require Collateral to cease business because of the risk that an immediate cessation of business could cause a disorderly collapse which would cause harm to customers (when it might have been possible to avoid such an outcome).

By January 2018, it was apparent, despite the efforts of the FCA, that there was unlikely to be an agreed resolution to the dispute with the directors of Collateral and on 29 January 2018, the FCA wrote to Collateral directing them to:

• cease conducting regulated activities.
• cease advertising itself as being authorised by the FCA.
• make the correct position known to its customers.
• to provide a full customer list to the FCA.

On the same day, the IP Register was changed to display the correct details.

We can confirm that we have received complaints concerning Collateral (UK) Ltd and are investigating the matter. As our investigation is ongoing (although nearing its final stages), we do not hold recorded information which would answer this question. We will of course continue to update complainants in accordance with the Complaints Scheme and we are working to finalise the complaints investigation as swiftly as we can.