CCR007 consumer credit data: how to complete the return

Should my figures be gross or net? 

Firms should use gross figures when completing the report. Firms should not net off business costs in this report.  

Should VAT be included?  

It depends on your firm type whether to include VAT or not. Firms should complete questions 1 and 2 on the same basis as their annual report and accounts: 

In some cases, VAT will have been included and not separated from their general income.  

For other firms, VAT is separated from their general income in their Annual Report and Accounts so this figure should be reported without VAT. 

Do not include VAT in question 6, otherwise your fees will be higher than they should be. 

Are question 1 and question 6 asking for the same thing and will my answer be the same? 

In many cases the answers will be the same. Both questions ask for income generated from regulated credit activities but question 6 is used to calculate your fees for the next financial year. The definition of ‘income’ for question 6 is specific and designed to minimise any risks of inconsistency or unfairness in the calculation of firms’ fees so it may differ from your accounts.  

If you report no income in question 1, you may need to provide a proxy measure of income in question 6. If this is your first return and it does not cover a full twelve months, you will need to ‘annualise’ the figure for question 6 to represent a twelve-month period. 

There are some more differences which are explained further on.  

If my firm hasn’t traded or I haven’t used my FCA permissions, what should I report in questions 1 and 6? 

In this situation, £0 can be reported.  

Should I include income from my unregulated business in questions 1 and 6? 

Firms should only report income from credit-related regulated activities. Please ensure that you understand what activities are regulated. You can find the full definition of all our regulated activities in PERG 2.7[3].

This should only include income derived directly from the credit-related regulated activities for which you have permission. You should exclude all incomes arising out of your main business of selling goods or services. See sections below for examples of revenue from credit-related activities. 

The permissions your firm holds are listed on the Financial Services Register[4]. PERG 2.7[3] of our Handbook outlines all our regulated activities and provides guidance on what is captured under each permission.

Secondary credit broking (other than by a domestic premises supplier) is where the sale of goods or non-financial services is the main business and broking is a secondary activity designed to help finance the purchase of those goods or services. For example, certain motor dealerships and high-street retailers that introduce customers to a finance provider.

What should I include in my income from credit-related regulated activities?

You should include any income received from activities that you have permission for.

For example, an item is sold for £1,200. The customer pays a £200 deposit but chooses to pay the rest of the balance on credit. The firm holds a ‘credit broking’ permission so can introduce the customer to a lender. The firm receives £1,000 from the lender plus a £50 commission for the introduction.

The income from a credit-related activity is £50. The £200 deposit and £1,000 loan do not need to be reported.

What if I don’t receive any income from my regulated credit broking activities?  

£0 can be reported in question 1 if no income is derived from the permissions that the firm holds. 

For example, if a retail firm holds the permission of 'credit broking' only and receives no commission or incentives from the finance companies they refer to, nor do they charge for the referral, they can report £0. In this scenario, the retail firm will get paid for the item in full, but for the specific activity of broking, no income was received. Selling of goods in itself is not a regulated activity. 

Please note that you may need to report a ‘fair value’ or ‘proxy’ measure of income for question 6 and you can find more information below.

Limited permission lending is lending where the sale of goods or non-financial services is the main business, and there is no interest or charges and the agreements are not hire - purchase or conditional sale agreements. For example, certain golf clubs or gyms allowing deferred payment for memberships.

What if I don’t receive any income from my regulated limited permission lending?  

Firms should not be earning any income from their regulated limited permission lending activities so your answer for question 1 should be 0. If you believe you are earning income from your regulated limited permission lending, please contact us[5].

What income should I report for my consumer hire activities?

You should report any income that relates to or results from the consumer hire agreement even if these costs are not specified within the hire contract (ie delivery and charges for damages).

For example, a firm hires out tractors and charges are broken down as follows:

• hire of tractor – payable each month
• any losses/damage to the tractor sustained whilst on hire
• annual servicing of the tractor whilst on hire
• delivery and pick up of tractor

All these payments are income generated by the regulated consumer hire agreement. The firm’s business might include servicing tractors which are not on hire – but this tractor is serviced during the contract period because it is on hire.

Firms must review the definition of a consumer hire agreement (PERG 2.7.19K[5]) to ensure they are only reporting on payments received for regulated hire contracts.

If no income is received for the debt advice, £0 can be reported in question 1. Any income received via grants / project funding / donations should not be included.

Total revenue covers all income received by the firm, regardless of whether it’s from credit-related activities or is unrelated to the credit element of your business.

You should record all income received by the firm, regardless of whether it’s from credit-related activities or not.

For example, a firm sells a car for £10,000. The customer also buys a spare tyre and some cleaning goods for £100 which are added to the total. The customer pays £3,000 as a deposit and pays the balance through a £7,100 loan arranged by the car dealer. The firm receives £50 commission from the finance company for introducing the customer. The consumer credit income would be the £50 and the non-consumer credit income would be the total of £10,100 received for the sale. The total income for this example would be £10,150.

• The firm sells a second car for £10,000 and the customer pays the full amount in cash without seeking credit. The entire sale is non-consumer credit income.
• The total income for the 2 sales would be £20,150, and therefore must all be reported under total revenue.

Total revenue covers all income received by the firm, regardless of whether it’s from credit-related activities or is unrelated to the credit element of your business.

Total revenue covers all income received by the firm, regardless of whether it’s from credit-related activities or is unrelated to the credit element of your business.

Total revenue covers all income received by the firm, regardless of whether it’s from credit-related activities or is unrelated to the credit element of your business. 

Review each individual credit-related activity and work out the number of transactions for each.

My customer was refused finance by the lender I introduced them to – is this still a transaction?

Referring the customer to a finance company should be recorded as a transaction, whether or not the customer is granted that credit by the finance company.

For example, a firm refers a customer to a finance company (Company A) but the customer is declined, so the firm then refers them to a second finance company (Company B). However, the customer isn’t happy with the terms of the agreement, so the firm then refers the customer a third time to a final finance company (Company C), and this time the agreement is taken up by the customer. This would be recorded as 3 transactions, regardless of whether it was for the same sale.

Review each individual credit-related activity and work out the number of transactions for each.

What should I include as a transaction for my consumer hire activities?

The number of new contracts entered during the reporting period. Do not include the number of old contracts being managed, or the payments received.

Review each individual credit-related activity and work out the number of transactions for each.

This question refers to all complaints received in relation to credit-related regulated activities only.

Should I include complaints about the product / service I am providing?

You should only include complaints that relate to the credit-related regulated activity carried out.

For example, a dental practice holds a 'credit broking' permission so they can refer patients to finance companies when they cannot afford the cost of the dental treatment upfront. Two of the patients who took out loans arranged by the practice complain that the credit repayments are too high:

• Patient 1 says the repayments are too high because the treatment was too expensive. This is a complaint about the dentist’s charges, not about the credit agreement.
• Patient 2 says the dentist pressured them into taking out the loan, denying them the opportunity to find a better deal on the open market. This is a credit-related complaint about the dentist’s conduct as a credit broker.

This question refers to all complaints received in relation to credit-related regulated activities only.

This question refers to all complaints received in relation to credit-related regulated activities only.

This question refers to all complaints received in relation to credit-related regulated activities only.

Review the drop down options and select the activity which generated the highest amount of turnover for the firm within the reporting period.

How do I answer if I have not used my permission(s) or done any business?

In both these instances, 'other' should be selected from the drop down.

How do I answer if none of my regulated activities generate any turnover or if I receive the same turnover for all my regulated activities?

In both these instances, 'other' should be selected from the drop down.

How do I answer if I have not used my permission(s) or done any business?

In both these instances, 'other' should be selected from the drop down.

How do I answer if none of my regulated activities generate any turnover or if I receive the same turnover for all my regulated activities?

In both these instances, 'other' should be selected from the drop down.

How do I answer if I have not used my permission(s) or done any business?

In both these instances, 'other' should be selected from the drop down.

How do I answer if none of my regulated activities generate any turnover or if I receive the same turnover for all my regulated activities?

In both these instances, 'other' should be selected from the drop down.

How do I answer if I have not used my permission(s) or done any business?

In both these instances, 'other' should be selected from the drop down.

How do I answer if none of my regulated activities generate any turnover or if I receive the same turnover for all my regulated activities?

In both these instances, 'other' should be selected from the drop down.

This question is based on the definition of income in our Fees manual within FEES 4 Annex 11B[5], with guidance at FEES 4 Annex 13 table 2[6]. See the relevant sections below for further information.  

We often look for ways to refine our methodology and guidance in the Fees manual. We recommend that you review the information in the links above before submitting your data to ensure you report correctly. As we use this data to calculate your fees, it’s very important you report correctly or you may end up paying too much. 

Firms will need to consider 'Fair Value' and the 'Proxy measure of income' as detailed within FEES 4 Annex 11B[8] to see if any additional income needs to be included.

What income should I include in question 6? 

In many cases it will be the same as question 1, but there are some important exceptions in question 6 which are intended to ensure all firms’ fees are calculated consistently. Some examples are set out below. However, please also review FEES 4 Annex 11B[10] for detailed information on what to include.

I carry out regulated credit activities but receive no income from them. What should I report?

If you carry out regulated activities you can’t normally report £0. You may need to calculate a ‘fair value’ or use a proxy measure. Please see below to ensure that you report correctly based on the regulated credit activities that you are carrying out.

What is an example of annual income as defined in FEES 4, Annex 11B?

A golf club introduces customers who prefer to pay their fees monthly to a finance company (the club holds the permission of 'credit broking'), and for each referral they receive £50.

The club refers 10 customers during the reporting year, so the firm would report an annual income of £500.

What is fair value?

This is an estimate of the amount the firm would have received for a regulated activity had it not made a business decision to waive or discount its charges. See a definition in FEES 4 Annex 11B (1)(C)[11]. 

When should I use fair value and how can it be calculated?

You should use a fair value if regulated credit activities and transactions have been carried out but income has not been received for every transaction.

For example, a firm act as a credit broker and refers customers to a finance company, but they do not get commission for all deals. They have introduced 10 people a year to a finance company, and out of the 10 introductions commission is only received for 5. For these 5 deals they get £50 in total (variable amounts for each referral). The other 5 transactions earn the firm no commission.

They would submit consumer credit income of £100 rather than the £50 received as income to consider fair value. Another way to think about this is to work out the average earned for each paid referral (ie £50 divided into 5, or £10), and multiply this by the total number of transactions (ie £10 x 10, or £100).

When should I use the proxy measure of income?

This would generally apply if your main business is supplying goods or services, and you receive no additional income from your credit broking or lending activities.

For example, a bicycle retailer earns no commission, fees, or incentives from referring customers to a finance company, and so its income from credit broking is £0. If they broker credit of £100,000, it should report 5% x £100,000 = £5,000 as the answer to question 6.

See the full rules about the proxy measure: FEES 4 Annex 11B (2)[12].

What is an example calculation for the proxy measure of income?

A firm earns no commission, fees, or incentives from any of the lenders to whom it refers its customers. However, it arranges loans which amount to the value of £10m. 

This firm would fall within the definition in FEES 4 Annex 11B (2) (a) (i) and (2) (a) (ii) (aa)[13] and would therefore need to report a proxy measure of income using the calculation in FEES 4 Annex 11B (2) (b). 

The proxy calculation would be: 

• Gross loan amount (ie total loan amount) brokered by the firm: £10m 
• 5% x £10m = £500,000
• Proxy income= £500,000

If the firm had incorrectly reported consumer credit income of £0 in question 6, other firms would have been paying its share of our regulatory costs. 

Where does the 5% figure come from?

We have set the proxy at 5%.

When we consulted on introducing the proxy calculation in October 2015 (CP15/14[-3] - paragraph 12.37, page 76), we explained that current broker charges ranged from 5% to 17% so we chose 5% as the lower end of the range.

Previously, firms had to use the Bank of England base rate plus 5% to calculate the proxy measure of income. However, following changes we consulted on in our November 2023 CP (CP23/22[-2]) we have set the proxy at 5% and removed the Bank of England Base rate from the calculation. We introduced these changes in our March 2024 Handbook Notice[-1] (PDF). 

I provide leaflets and posters to promote various credit options and providers. I do not know which customers will use these options to facilitate payment. How do I apply the proxy measure of income? 

Since you are not able to know who, if anyone, took out finance because of the leaflets or posters you have no basis for calculating the gross loan amount. Although the proxy measure of income does apply in this instance, the proxy measure calculation would not be possible. For any credit broking that occurred in this manner, you would record £0.

Firms using multiple methods of credit broking would need to review each method to ensure they are applying the proxy measure of income correctly. For example, for any direct referrals made, there would be a basis for calculating the gross loan amount.

When should I use the proxy measure of income?

This would generally apply if your main business were to supply goods or services, and you receive no additional income from your credit broking or lending activities.

The full rules about the proxy measure can be found at FEES 4 Annex 11B (2)[14].

Where does the 5% figure come from?

We have set the proxy at 5%.

For example, a dental practice brokers £50,000 worth of loans on behalf of its patients to facilitate treatment which it earns no commission, incentives, or fees on. 

• The proxy calculation would be: 5% x £50,000 = £2,500 
• Proxy income = £2,500 

When we consulted on introducing the proxy calculation in October 2015 (CP 15/14 - paragraph 12.37, page 76), we explained that current broker charges ranged from 5%-17% so we chose 5% as the lower end of the range. 

Previously, firms had to use the Bank of England base rate plus 5% to calculate the proxy measure of income. However, following changes we consulted on in our November 2023 CP (CP23/22[16]) we have set the proxy at 5% and removed the Bank of England Base rate from the calculation. We introduced these changes in our March 2024 Handbook Notice[17] (PDF).

To determine the total annual income, a consumer hire firm should calculate the total revenue received over the period of the lease minus depreciation of the asset over the same period. Please see FEES 4 annex 11B[18] for further information.

Not for profit debt advice bodies will not be charged any annual fees.   Therefore, £0 can be reported. Please check the definition of a not-for-profit debt advice body[-11] to ensure that the correct figure is reported.