Top Takeaways - AML and Consumer Credit: What housing associations need to know

Yesterday we hosted our AML and Consumer Credit seminar to coincide with the launch of our new Financial Services Regulation team. We've collated our top 5 takeaways from the seminar below.

1. Are you under registered or over registered for AML and consumer credit? We have developed a questionnaire which can be sent to different areas of the business to help us assess whether or not your AML registrations and consumer credit permissions are correct. We can then advise on a course of action.
2. The future of the economic crime levy (ECL) is uncertain. The ECL is very punitive for housing associations where the regulated part of your business is often small and low risk. The Government will undertake a review of the ECL by the end of 2027 and the NHF and CHC have issued consultations to their members on its impact. In the interim some housing associations may have to consider whether it is worth continuing the regulated activities which bring them within the scope of the ECL or whether these activities could be outsourced or restructured. 
3. Consumer Duty. The FCA is now heavily focused on Consumer Duty and will expect to see it embedded in housing association’s business strategies and fully implemented in the processes carried out in relation to regulated activities. 
4. Are you ready, willing and organised? This is an FCA expectation of all firms who are applying for new or amended permissions for regulated activities and you need to be able to demonstrate this clearly. What activities will you be carrying out, who will your customers be and how you will go about providing the product or service? This also means you will need to have a raft of FCA-compliant policies in place.
5. Failure to prevent fraud offence: are you ready? Organisations falling within the scope of this new offence must have “reasonable procedures” to prevent fraud in place by 1 September 2025 or face substantial fines. We can advise on what “reasonable procedures” look like, provide policy templates and guide you through that process from start to finish.

For more information, please do not hesitate to contact a member of our Financial Services Regulation team.