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Portrait ofJames Dickie

James Dickie

Partner

Contact
CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
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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Education

  • 2011 – LPC, BPP Law School, London 
  • 2010 – LL.B., Durham University, Durham 
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Feed

28/03/2024
FCA Publishes Finalised Guidance on Financial Promotions on Social Media
The Financial Conduct Authority (“FCA”) has published its finalised guidance on financial promotions on social media (FG24/1) (the “Guidance”). This follows a consultation carried out by the FCA...
28/03/2024
FCA Publishes Finalised Guidance on Financial Promotions on Social Media
The Financial Conduct Authority (“FCA”) has published its finalised guidance on financial promotions on social media (FG24/1) (the “Guidance”). This follows a consultation carried out by the FCA...
19/03/2024
HM Treasury launches consultation on improving the effectiveness of the...
HM Treasury (“HMT”) has launched a consultation (the “Con­sulta­tion”) on improving the effectiveness of Money Laundering Regulations 2017 (“MLRs”). The Consultation follows HMT’s 2022 review...
19/03/2024
HM Treasury launches consultation on improving the effectiveness of the...
HM Treasury (“HMT”) has launched a consultation (the “Con­sulta­tion”) on improving the effectiveness of Money Laundering Regulations 2017 (“MLRs”). The Consultation follows HMT’s 2022 review...
06/03/2024
FCA sends Dear CEO letter to firms in warning over money laundering failings
The Financial Conduct Authority (“FCA”) has sent a Dear CEO letter (the “Letter”) to Annex 1 Firms warning them about common failings found in their ability to prevent money laundering, terrorist...
06/03/2024
FCA sends Dear CEO letter to firms in warning over money laundering failings
The Financial Conduct Authority (“FCA”) has sent a Dear CEO letter (the “Letter”) to Annex 1 Firms warning them about common failings found in their ability to prevent money laundering, terrorist...
31/10/2023
Taking security in relation to e-money and e-money accounts
This article first appeared in Thomson Reuters Practical Law, Oct 2023 Key takeaways:se­cur­ity can be taken over e-money and e-money accountse-money accounts cannot be blocked in the same way that traditional...
15/09/2023
FCA-authorised firms and The Economic Crime (Anti-Money Laundering) Levy...
If your firm is authorised by the Financial Conduct Authority (“FCA”) but is not within scope of the Money Laundering Regulations 2017, you may want to check your FCA fee statement. This is because...
02/03/2023
Regulation of BNPL
On 14th February 2023, HM Treasury (“HMT”) opened a consultation on the government’s draft legislation to regulate certain types of currently exempt interest-free “Buy-Now Pay-Later” (“BNPL”)...
01/03/2023
Regulation of BNPL
On 14th February 2023, HM Treasury (“HMT”) opened a consultation on the government’s draft legislation to regulate certain types of currently exempt interest-free “Buy-Now Pay-Later” (“BNPL”)...
08/02/2023
E-money and e-money accounts - a guide for lenders
The development of the fintech sector over the last ten years has transformed payment systems with more individuals and businesses moving away from cash payments to using electronic money (“e-money”)...
07/02/2023
E-money and e-money accounts – a guide for lenders
The development of the fintech sector over the last ten years has transformed payment systems with more individuals and businesses moving away from cash payments to using electronic money (“e-money”)...