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Portrait of James Dickie

James Dickie

Senior Associate

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

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”)...
17/06/2022
Con­sumer Cred­it Act to be re­formed
The Gov­ern­ment has an­nounced that it is com­mit­ting to re­form the Con­sumer Cred­it Act 1974 (“CCA”), which reg­u­lates lend­ing, in­clud­ing cred­it cards and per­son­al loans. This re­form is part of a drive...
17/06/2022
Lenders told to sup­port con­sumers strug­gling with the cost of liv­ing
The FCA has sought to ad­dress the im­pact of the rising cost of liv­ing on con­sumers by writ­ing to Chief Ex­ec­ut­ives of over 3,500 lenders re­mind­ing them of the stand­ards they are ex­pec­ted to up­hold (the...
17/06/2022
Lenders told to sup­port con­sumers strug­gling with the cost of liv­ing
Treat­ing cus­tom­ers fairly Treat­ing cus­tom­ers fairly, both old and new, is the prom­in­ent theme of this “Dear CEO” let­ter, with the FCA high­light­ing that the im­pact on cus­tom­ers will not just be fin­an­cial...
17/06/2022
Con­sumer Cred­it Act to be re­formed
What will change? The gov­ern­ment in­tends to: Move much of the CCA from stat­ute to sit un­der the Fin­an­cial Con­duct Au­thor­ity (“FCA”). This will bet­ter place the FCA to re­spond swiftly to de­vel­op­ments...
25/10/2021
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...
22/10/2021
Reg­u­la­tion of Buy-Now Pay-Later products fast ap­proach­ing
1. Cred­it Brok­ing Brokers of BN­PL products and oth­er short term in­terest free agree­ments are not cur­rently “cred­it brok­ing” be­cause brok­ing such agree­ments is not with­in the reg­u­lat­ory peri­met­er...
27/07/2021
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...
27/07/2021
UK Gov­ern­ment ex­plores AML re­form for Open Bank­ing pay­ment ser­vice pro­viders
The per­ceived dis­con­nect between the com­pli­ance bur­den on ac­count in­form­a­tion ser­vice pro­viders (AISPs), who provide “in­form­a­tion only” ser­vices to cus­tom­ers to en­able them to view con­sol­id­ated fin­an­cial...