The regulated activity of ‘advising on P2P agreements’ and the impact this has for your firm’s permissions

With effect from 6 April 2016, the FCA has automatically varied the permissions of all firms who currently hold permissions of ‘advising on investments’ to add the new regulated activity of ‘advising on P2P agreements’. This change has also affected firms who give advice on non-investment insurance contract and those whose main business activity is not to provide investment advice, e.g. general insurance intermediaries.

In the 2014 Budget, it was announced by the government that the Innovative Finance ISA (IFISA) would be introduced and this would allow P2P agreements to be included within the ISA tax wrapper.
The new permission does not bring any additional regulatory requirements or additional fees, but firms are reminded that suitability applies to the activity of advising on P2P agreements.
Firms who do not intend to carry out the activity of advising on P2P agreements now or in the future can apply to remove this activity without any fees being incurred by submitting a short form to the FCA which is located on their website. The short form is only available until 6 October 2016, and any changes after that date will need to be submitted via the Connect system. Should you need to re-add the P2P advice activity in the future, this change of permission will incur a fee of £250.
If you would like any assistance in completing the form, please do not hesitate to contact us.

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