Those clubs who are currently operating direct debit schemes for subscriptions should be fully aware of the new legislation regarding instalment payments and interest/admin fees. The previous GCMA articles detailing this can be found here:
Financial Conduct Authority Credit Rules Update
Consumer credit – instalment exemption extended
We’re sure that some clubs have decided to apply for FCA Authorisation, or are using a broker such as Premium Credit, and as such the charging of interest will be legally permissible.
For those clubs that have decided to dispense with instalment charges, and are going to continue with a direct debit scheme under the FCA Exemption, then it is advised that they apply to extend their interim permission until the end of their current subscription year. This can be done on application to the FCA by email to [email protected], and will ensure that the current direct debit agreements, provided they were set up before 18th March 2015, comply fully with FCA Regulations.
Once this year’s final direct debit instalment has been received then you can either inform FCA that you are now exempt by completing their Consumer Credit Notification Survey or you can cancel your interim permission on FCA’s website. It may well be advisable to do both, but the latest it can be done is 31st March 2016.
By GCMA
