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Commercial Finance Launch Programme · Stage 4 of 10
Get Compliant
Put the regulated basics in place to the FCA’s standard, then adopt your network’s, compliance’s or the NACFB’s wording rather than drafting your own interpretation.
How long
~3–5 days
You’ll have
Commission disclosure placed, an AML framework under the right supervisor, and a read on Consumer Duty and data
Steps
3 steps
Resources
2 resources
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01 Step 01
Step 01
Nail commission disclosure
Commission disclosure is the hottest regulatory topic in broking, so how you disclose what a lender pays you has to be right from day one.
Do it yourself
- Follow the direction of travel at a signposting level. From the current position, the FCA has banned discretionary commission and requires disclosure of the existence and nature of commission on regulated credit.
- Note the Supreme Court’s ruling of August 2025: brokers do not automatically owe fiduciary duties, but non-disclosure of commission can still be unfair under consumer-credit law depending on factors including the size, nature and manner of the disclosure, and the FCA has confirmed a redress scheme.
- Adopt the safe posture the sector and the NACFB advise, and do not wait: disclose the existence and nature of your commission proactively and prominently, in your financial promotions and when you recommend, and be ready to disclose the amount on request, on regulated and unregulated deals alike.
- Take your Terms of Business and recommendation wording from your network or compliance function (the NACFB provides member templates) and adopt theirs rather than drafting your own interpretation.
- Bake the agreed disclosure into every client-facing touchpoint.
Common mistake · Copying a generic disclosure line off another broker’s site instead of using your network’s approved wording, and burying it where it is not prominent.
Time~1–2 days to implement supplied templates Cost£0 to indicative low hundreds if via a compliance consultant DifficultyMediumResource for this step
PDFCommission disclosure placement checklist
Every place disclosure must appear (financial promotions, Terms of Business, recommendation, website, portal), each with a wording-source field. It does not supply the wording.
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02 Step 02
Step 02
Stand up AML and financial-crime controls
Handling client and lender money-flows brings anti-money-laundering obligations, and you must be under the correct supervisor and run basic controls.
Do it yourself
- Confirm who supervises your AML: if you are FCA-authorised, the FCA; if not, you may need HMRC anti-money-laundering registration depending on your activities, so confirm which applies with your network or compliance function.
- Note that supervision is being reformed, with the FCA set to take on more, so check the current position rather than assume it.
- Put in place customer due diligence and identity checks, source-of-funds awareness, and suspicious-activity procedures, using your trade body’s or network’s framework.
- Keep the records the regime requires.
Common mistake · Assuming "the lender does the AML" and doing none, when you have your own obligations as the introducer.
Time~1–2 days to set up CostHMRC AML registration indicative around £300 per premises plus a fit-and-proper fee where applicable, confirm the current figure DifficultyMediumResource for this step
PDFAML starter pack
A customer due diligence checklist, an ID-verification log, and a who-is-my-supervisor decision box to confirm with your network, compliance or HMRC.
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03 Step 03
Step 03
Consumer Duty and data protection where they apply
Where you touch consumer credit or regulated business, the FCA’s Consumer Duty raises the bar, and every broker has data-protection and record-keeping duties on financial data whatever the perimeter.
Do it yourself
- Confirm with your network or compliance function whether and where Consumer Duty applies to your mix: it bites on consumer and regulated activity, and you do not self-declare it in or out.
- Where it applies, adopt your network’s Consumer Duty framework for your communications, fair value and client outcomes.
- Put in place a simple, secure record-keeping and data-retention practice that ties to your ICO registration and your client portal.
Common mistake · Treating Consumer Duty as "only for consumer lenders" and missing that consumer credit broking, for example for a sole trader, can pull you in.
Time~1–2 days Cost£0 beyond software DifficultyMedium
What you’ll have after this stage
- A commission-disclosure approach using your network’s wording, placed everywhere it must appear
- An AML framework with the right supervisor confirmed
- A clear read on where Consumer Duty applies
- Secure record-keeping and data retention