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James Dickie

Senior Associate

James Dickie

Senior Associate

Contact
T +44 20 7367 3421
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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Expertise

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20 July 2020
FCA Dear CEO Let­ter and Re­lease of Fi­nal­ised Guid­ance on Coronavir­us and...
The FCA has fi­nal­ised ad­di­tion­al guid­ance and pub­lished a Dear CEO let­ter for pay­ments in­sti­tu­tions and e-money in­sti­tu­tions, to strengthen the way in which they look after cus­tom­ers’ money. Sam Robin­son...
Publication Financial Services & Regulation
20 November 2020
FCA con­firms up­dated sup­port for con­sumer cred­it cus­tom­ers
The FCA has pub­lished up­dated guid­ance to firms con­firm­ing the en­hanced sup­port that should be made avail­able to con­sumer cred­it cus­tom­ers who are fa­cing pay­ment dif­fi­culties as a res­ult of coronavir­us...
Law-Now Coronavirus (COVID-19)
1 June 2020
Coronavir­us and safe­guard­ing cus­tom­er­s' funds: pro­posed guid­ance for pay­ment...
The FCA has launched a con­sulta­tion on ad­di­tion­al guid­ance for pay­ments in­sti­tu­tions and e-money in­sti­tu­tions, to strengthen the way in which they look after cus­tom­ers’ money. Sam Robin­son, James Dick­ie...
Publication Banking & Finance
12 November 2020
Con­sumer Cred­it Up­date: Changes to No­tices – what needs to be done?
HM Treas­ury has pub­lished The Con­sumer Cred­it (En­force­ment, De­fault and Ter­min­a­tion No­tices) (Coronavir­us) (Amend­ment) Reg­u­la­tions 2020 (the Amend­ing Reg­u­la­tions), com­ing in­to force on 2 Decem­ber 2020...
Law-Now Banking & Finance
04 November 2020
FCA an­nounces fur­ther pro­pos­als to sup­port mort­gage and con­sumer cred­it...
After the Gov­ern­ment’s an­nounce­ment on 31 Oc­to­ber 2020 of an­oth­er na­tion­wide lock­down, the FCA pub­lished a state­ment pro­pos­ing to up­date its tem­por­ary guid­ance on mort­gages to sup­port bor­row­ers who...
Law-Now Coronavirus (COVID-19)
28 July 2020
FCA to ban mo­tor fin­ance dis­cre­tion­ary com­mis­sion mod­els
Fol­low­ing a con­sulta­tion in Oc­to­ber 2019, dis­cussed in our art­icle here, the FCA has con­firmed that it will in­tro­duce a ban on dis­cre­tion­ary mo­tor fin­ance com­mis­sion mod­els. In light of con­sulta­tion feed­back...
Law-Now Banking & Finance
27 July 2020
Coronavir­us and cus­tom­ers in tem­por­ary fin­an­cial dif­fi­culty: pro­pos­als...
The FCA has an­nounced pro­pos­als to ex­tend a series of tem­por­ary meas­ures de­signed to help cus­tom­ers hold­ing in­sur­ance and premi­um fin­ance products and who may be ex­per­i­en­cing tem­por­ary fin­an­cial dif­fi­culty...
Law-Now Coronavirus (COVID-19)
17 July 2020
FCA pub­lishes Fi­nal Guid­ance and Dear CEO let­ter on Coronavir­us and Safe­guard­ing...
The FCA has re­leased its fi­nal­ised guid­ance (the “Guid­ance”) for pay­ment in­sti­tu­tions’ (“PIs”) and elec­tron­ic money in­sti­tu­tions’ (“EMIs”) (to­geth­er known as “Pay­ment Firms”) in the...
Law-Now Coronavirus (COVID-19)
17 July 2020
FCA con­firms fur­ther sup­port for a range of cus­tom­ers, in­clud­ing mo­tor...
The FCA has con­firmed the sup­port avail­able for mo­tor fin­ance, high-cost short-term cred­it, buy now pay later, rent-to-own and pawn­brok­ing cus­tom­ers who con­tin­ue to ex­per­i­ence pay­ment dif­fi­culties due...
Law-Now Coronavirus (COVID-19)
06 July 2020
FCA con­firms fur­ther sup­port for con­sumer cred­it cus­tom­ers
Fol­low­ing the re­lease of pre­vi­ous guid­ance, on 1 Ju­ly 2020, the FCA con­firmed the sup­port cer­tain users of con­sumer cred­it products will re­ceive if they con­tin­ue to ex­per­i­ence tem­por­ary pay­ment dif­fi­culties...
Law-Now Coronavirus (COVID-19)
03 July 2020
FCA an­nounces pro­pos­als to fur­ther sup­port mo­tor fin­ance and high cost...
The FCA has today an­nounced fur­ther pro­pos­als in the form of draft guid­ance (the Pro­pos­als) build­ing upon the tem­por­ary fin­an­cial re­lief already offered to users of mo­tor fin­ance and high cost cred­it...
Law-Now Banking & Finance
01 June 2020
FCA pro­posed guid­ance for pay­ment in­sti­tu­tions and e-money in­sti­tu­tions:...
The Fin­an­cial Con­duct Au­thor­ity (the “FCA”) has set out a short con­sulta­tion (the “Con­sulta­tion”) which pro­poses ad­di­tion­al tem­por­ary guid­ance (the “Pro­posed Guid­ance”) to strengthen pay­ment...
Law-Now Coronavirus (COVID-19)
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