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FCA

FCA

Financial Conduct Authority (UK)

Low Impact

FCA imposes immediate requirements on Curtis Faraday Limited over debt advice and IVA-related consumer harm concerns

Published

Sep 18, 2026

Effective

Jun 30, 2026

Topics

Debt advice, Individual Voluntary Arrangements, Consumer protection, Threshold Conditions, Own-initiative requirements, Record keeping, Customer communications, Governance and controls, Conflicts of interest

Executive Summary

The FCA has imposed immediate requirements on Curtis Faraday Limited under section 55L of the Financial Services and Markets Act 2000 after concluding that the firm presents an ongoing and immediate risk of consumer harm. The notice restricts the firm from accepting new customers or referrals involving debt-related, IVA-related, insolvency-related or Article 72H RAO-related customer activity without prior FCA written consent. It also requires the firm to preserve business records in the UK, publish website notices, signpost certain customers to MoneyHelper and notify customers referred to debt solution providers in the previous 12 months. The FCA’s action is based on concerns about incomplete and inconsistent regulatory responses, inadequate evidence of compliant customer journeys, governance weaknesses, possible customer coaching during fact-finding and advice, and commercial incentives that may bias debt-solution outcomes. The requirements took immediate effect on 30 June 2026 and remain in force unless varied or cancelled by the FCA. The case is firm-specific but is a clear supervisory signal for debt advice firms using referral or in-house insolvency models.

What Changed

newImmediate restriction on new debt and IVA-related business

Previous

The firm held permissions for debt counselling and debt adjusting and operated as a debt advice firm.

New

New customer and referral acceptance for the specified activity categories is restricted with immediate effect.

newRecords preservation and UK location requirement

Previous

The FCA found the firm had not evidenced complete customer journeys and had not maintained or provided reliable records in response to supervisory requests.

New

The firm must retain records in a UK location and make them available promptly to the FCA or a person named by the FCA.

newWebsite notice obligation

Previous

No equivalent public notice requirement applied under this notice before 30 June 2026.

New

The firm must display the FCA-agreed notice prominently on all relevant websites.

newCustomer notification and MoneyHelper signposting

Previous

Customers were not subject to this specific FCA-directed notification and signposting process under the notice.

New

The firm must complete customer communications and signposting within the deadlines stated in the notice.

newPost-notification evidence to the FCA

Previous

The firm had repeatedly provided incomplete, inconsistent or inaccurate information to the FCA, including under section 165 information requirements.

New

The notice creates a specific evidence pack requirement linked to the customer-notification exercise.

Business Impact

Who is affected

Directly affected

Curtis Faraday Limited, its senior managers, staff, websites, records owners and customer communication teams.

Indirectly affected

existing customers awaiting outcomes, customers referred to debt solution providers in the last 12 months, referral partners, connected insolvency or debt solution providers, and UK FCA-authorised debt advice firms with similar referral or in-house debt solution models.

Jurisdictions

United Kingdom

Business processes

New customer onboarding and referral acceptance, Debt advice and IVA suitability assessment, Customer fact-find, affordability and file-recording controls, Website disclosure governance, Customer notification and vulnerability handling, Regulatory information request and section 165 response management, Senior manager governance, conflicts and business model oversight

Estimated effort

High

Compliance risk

High

Affected Reports

New customer and referral intake restriction controlUK records preservation and FCA location notification fileWebsite supervisory notice publication controlCustomer notification templates, recipient list and completion attestationCustomer journey evidence pack, including call recordings, messages, advice documents and file review materials
FieldValidation rule
Customer/referral acceptance statusThe firm must not accept new customers or referrals for debt-related, IVA-related, insolvency-related or Article 72H RAO-related customer activity without prior written FCA consent.
Record retention locationAll relevant physical and electronic business records must be preserved in original or identical-copy form at a UK location notified to the FCA by 5pm on 7 July 2026.
Website notice content and placementThe firm must publish an FCA-agreed notice in a prominent place on every website in its name or operated by it by 5pm on 7 July 2026.
Customer notification populationThe firm must notify all customers referred to a debt solution provider in the 12 months before 30 June 2026 by close of business on 13 July 2026.
FCA post-notification evidenceWithin 24 hours of making notifications, the firm must provide template notifications, recipient list and confirmation that all relevant parties were notified to the best of its knowledge.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    Confirmed actionStep 1 of 7

    immediately block new customer and referral intake for the restricted debt, IVA, insolvency and Article 72H RAO-related activity unless FCA written consent is obtained.

  2. 2
    Confirmed actionStep 2 of 7

    complete the records preservation, website notice, customer notification and FCA evidence submissions within the deadlines set out in the notice.

  3. 3
    AI generatedStep 3 of 7

    run a board-led attestation that all websites, trading names, lead generators and referral channels have been identified and included in the restriction and notice process.

  4. 4
    AI generatedStep 4 of 7

    perform a privileged customer-file review covering affordability evidence, call recordings, WhatsApp or digital messages, advice outcomes and referral rationale, prioritising customers referred to IVA or other remunerated solutions.

  5. 5
    AI generatedStep 5 of 7

    reassess referral-fee, introducer and in-house debt solution models against FCA CONC debt packager remuneration rules, conflict management expectations and Consumer Duty outcome testing.

  6. 6
    AI generatedStep 6 of 7

    test whether SMF responsibilities, close links, controller influence, director loans, prudential resources and governance changes are fully documented and capable of FCA supervisory review.

  7. 7
    AI generatedStep 7 of 7

    strengthen section 165 response governance by maintaining complete request logs, evidence inventories, data-gap explanations and accountable sign-off before submission to the FCA.

Timeline

effective date

Jun 30, 2026

FCA dated the First Supervisory Notice and imposed the requirements on Curtis Faraday Limited with immediate effect.

implementation

Jul 7, 2026

Deadline of 5pm for Curtis Faraday to notify the FCA of the UK location where preserved records are held and to publish the FCA-agreed website notice.

implementation

Jul 13, 2026

Close-of-business deadline for Curtis Faraday to notify in writing all customers referred to a debt solution provider in the 12 months from the date of the notice.

other

Jul 16, 2026

Deadline for Curtis Faraday to provide written representations to the FCA and to notify any request to make oral representations, unless the FCA permits a later date.

other

Jul 30, 2026

Deadline stated in the notice for Curtis Faraday to refer the matter to the Upper Tribunal.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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