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Portrait of James Dickie

James Dickie

Senior Associate

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English

James qualified into the CMS UK Financial Services Regulatory team in August 2013, having trained with the firm. Since qualifying James has developed a particular focus on consumer financial service products, and the consumer credit and payment service markets in particular. He advises a wide range of consumer credit clients, including both retail banks and high street retailers, as well as multiple payment service providers, such as banks, new fintech entrants, and payment instrument issuers. James has particular expertise in advising captive motor finance providers and firms with unique distribution strategies (whether they be technology based or otherwise).

James has experience of all matters within the regulated product lifecycle, including assisting with the authorisation of lenders/providers and implementing FCA compliance processes; advising on the design, distribution and operation of consumer products; drafting pre-contract information, customer facing agreements/terms of business and post-contractual notices; and advising on compliance with all conduct of business rules applicable to regulated entities. Clients have commended James for his extremely practical and commercial approach in light of increasing regulatory rules and principles within the credit and payment sectors. His knowledge of both the statutory and regulatory regimes is invaluable to clients.

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Relevant experience

  • A significant insurance provider on its compliance with the FCA Consumer Credit sourcebook with collecting debts relating to insurance policies which had been financed via a credit agreement.
  • A credit providers on the design of their broker networks, their direct sale websites and apps, and their compliance with consumer rights legislation, when selling various finance agreements and additional services.
  • A debt sale agreement relating to consumer credit agreements, which incorporated a disclosure process relating to the portfolio's issues with NOSIAs and PPI.
  • A large high street bank on the terms and conditions for its credit card product.
  • Multiple credit providers on issues relating to deficiencies within their statutory notices, the resulting remediation programmes and discussions with the FCA on the issues.
  • Various deposit broking platforms with establishing their business models and advising on their interactions with deposit takers.
  • A specialist deposit taker on the various liquidity, FSCS and AML implications of accepting deposits via different legal structures.
  • A deposit taker on its obligations under the UK's Recovery and Resolution regime, with a particular focus on interactions with 3rd party suppliers.
  • On CHAPS participation documentation for a large UK deposit taker.
  • A new e-money based supplier payment structure being implemented in the travel agency industry.
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  • 2011 – LPC, BPP Law School, London 
  • 2010 – LL.B., Durham University, Durham 
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Reg­u­la­tion of Buy-Now Pay-Later products fast ap­proach­ing
HM Treas­ury has pub­lished the highly an­ti­cip­ated con­sulta­tion pa­per (“CP”) set­ting out policy op­tions to achieve a pro­por­tion­ate ap­proach to reg­u­la­tion of buy-now-pay-later (“BN­PL”) products...
UK Gov­ern­ment ex­plores AML re­form for Open Bank­ing pay­ment ser­vice pro­viders
On 22 Ju­ly 2021, HM Treas­ury pub­lished a con­sulta­tion pa­per cov­er­ing vari­ous pro­posed amend­ments to the UK’s anti-money laun­der­ing (AML) frame­work, in­clud­ing the po­ten­tial re­mov­al of ac­count in­form­a­tion...
Con­sumer cred­it in­form­a­tion sheets up­dated by FCA
The FCA has pub­lished re­vised con­sumer cred­it in­form­a­tion sheets on its webpage. In ac­cord­ance with sec­tion 86A of the Con­sumer Cred­it Act 1974, lenders are re­quired to in­clude a copy of the rel­ev­ant...
De­fault No­tices for Con­sumer Cred­it Agree­ments: Have you made the changes?
Firms are re­minded that the re­quired amend­ments to de­fault no­tices must be made by 2 June 2021. The Con­sumer Cred­it (En­force­ment, De­fault and Ter­min­a­tion No­tices) (Coronavir­us) (Amend­ment) Reg­u­la­tions...
Con­sumer cred­it firms: changes to SECCI im­min­ent
As pre­vi­ously re­por­ted, con­sumer cred­it firms must make changes to their pre-con­tract con­sumer cred­it in­form­a­tion forms. These changes are now im­min­ent and must be made from 1 June 2021. Which firms are...
The FCA and PRA ask banks to re­view their ar­range­ments with de­pos­it ag­greg­at­ors
On 14 April 2021, the Fin­an­cial Con­duct Au­thor­ity (FCA) and Pruden­tial Reg­u­la­tion Au­thor­ity (PRA) sent a “Dear CEO Let­ter” to the chief ex­ec­ut­ive of­ficers of banks and build­ing so­ci­et­ies re­gard­ing...
Gov­ern­ment acts to bring Buy-Now-Pay-Later products with­in the reg­u­lat­ory...
Fol­low­ing the Woolard Re­view (“the Re­view”) earli­er this year, HM Treas­ury an­nounced plans to bring Buy-now-pay-later (“BN­PL”) cred­it agree­ments in­to reg­u­la­tion. The Gov­ern­ment has now brought...
The Woolard Re­view: Buy-now-pay-later firms to be reg­u­lated by the FCA
In Septem­ber 2020, the FCA re­ques­ted its former in­ter­im CEO, Chris Woolard, to con­duct a re­view of change and in­nov­a­tion in the un­se­cured cred­it mar­ket. De­tails of the Re­view were pub­lished in Oc­to­ber...
An Up­dated Ap­proach: the FCA’s new Con­sulta­tion Pa­per CP21/3 on Pay­ment...
The Fin­an­cial Con­duct Au­thor­ity (“FCA”) pub­lished Con­sulta­tion Pa­per CP21/3 (the “Con­sulta­tion Pa­per”) on 28 Janu­ary 2021 pro­pos­ing: amend­ments to the tech­nic­al stand­ards on strong cus­tom­er...
FCA up­date to guid­ance on mort­gage and con­sumer cred­it re­pos­ses­sions, in­clud­ing...
The FCA has up­dated the Tailored Sup­port Guid­ance for firms on con­sumer cred­it and mort­gage re­pos­ses­sions. The reg­u­lat­or in­vites com­ments on the draft guid­ance by 10am on 18 Janu­ary 2021. In Novem­ber...
UK reg­u­lat­or pub­lishes port­fo­lio strategy let­ter for main­stream con­sumer...
The Fin­an­cial Con­duct Au­thor­ity (FCA) has pub­lished a 'Dear Board of Dir­ect­or­s' let­ter it had sent to main­stream con­sumer cred­it lenders (MC­CL). The let­ter, pub­lished on Decem­ber 2, is rel­ev­ant to firms...
Firms must up­date their doc­u­ment­a­tion to ex­clude ref­er­ence to SECCI
In a re­cent de­vel­op­ment, the stat­utory in­stru­ment ad­dress­ing the Stand­ard European Con­sumer Cred­it In­form­a­tion sheet (“SECCI”) trans­ition was laid. The Fin­an­cial Ser­vices and Eco­nom­ic and Mon­et­ary...