FCA
Financial Conduct Authority (UK)
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
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.
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.
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.
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.
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
| Field | Validation rule |
|---|---|
| Customer/referral acceptance status | The 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 location | All 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 placement | The 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 population | The 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 evidence | Within 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
- 1Confirmed 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.
- 2Confirmed actionStep 2 of 7
complete the records preservation, website notice, customer notification and FCA evidence submissions within the deadlines set out in the notice.
- 3AI 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.
- 4AI 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.
- 5AI 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.
- 6AI 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.
- 7AI 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.
- Supervisory noticeFinancial Conduct AuthorityJun 30, 2026First Supervisory Notice: Curtis Faraday Limited ↗
https://www.fca.org.uk/publication/supervisory-notices/curtis-faraday-limited-2026.pdf
- Handbook guidanceFinancial Conduct AuthorityDate not specifiedFCA Handbook: SUP 6B - FCA's power to vary or cancel Part 4A permission on its own initiative and to impose requirements ↗
https://handbook.fca.org.uk/handbook/SUP/6B/
- Handbook guidanceFinancial Conduct AuthorityDate not specifiedFCA Handbook: COND - Threshold Conditions ↗
https://handbook.fca.org.uk/handbook/COND/
- Handbook rulesFinancial Conduct AuthorityDate not specifiedFCA Handbook: CONC 8.3 - Debt counselling and debt adjusting ↗
https://handbook.fca.org.uk/handbook/CONC/8/3.html
- Consumer guidance and advice locatorMoneyHelperDate not specifiedDebt Advice Locator ↗
https://www.moneyhelper.org.uk/en/money-troubles/dealing-with-debt/debt-advice-locator
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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