Licence Renewals
A high cost credit provider's licence is valid for a period of five years and a Renewal Application Authorisation High Cost Credit Provider (Guidance Note for Completing an Application for Authorisation as a HCCP) must be submitted by the firm to the Central Bank. Approximately 8 weeks before a firm’s licence is due to expire, the Central Bank will issue a renewal letter to the firm. This letter includes a deadline of approximately four weeks by which the firm must return the completed application form including the specific information and documentation requirements set out therein. This timeline gives the firm 4 weeks to submit the required application material and gives the Central Bank 4 weeks to process the application. The onus is on the firm to submit its Renewal Form sufficiently in advance of the date on which its licence is due to expire, irrespective of whether or not it receives a renewal letter from the Central Bank.
The authorisation process for renewal applications is not subject to the same service standards as for new applications. The service standard timeframe to which the Central Bank has committed for the renewal authorisation process is to issue a decision on all renewal applications before the expiry of the firm’s current licence.
The completed Renewal Form, along with all relevant accompanying material, should be submitted in electronic format to the Central Bank by email to [email protected].
The Key Steps in the Renewal Application Process
Stage 1 - Acknowledgement
The Central Bank will acknowledge receipt of a renewal application submitted by the firm within 3 working days of receipt.
Stage 2 - Key Information Check
The Central Bank will then check that the renewal application material submitted contains all the key information and documentation required to proceed to the assessment phase. If the application contains the required information, the Central Bank will commence the assessment phase. If the application does not contain sufficient material to proceed to the assessment phase the Central Bank may return the application to the firm and request that it be re-submitted in full.
Stage 3 - Assessment Phase
Where sufficient information has been received, the Central Bank will then proceed to the assessment phase of the renewal application process. The application material submitted will be reviewed against the relevant authorisation requirements to determine whether sufficient information has been provided to reach a determination in respect of the renewal application. The Central Bank will issue initial comments to the firm based on its review of the renewal application material submitted and any subsequent comments based on its review of responses submitted by the firm.
The renewal application process is not subject to the 90 working days clock referred to above in respect of new applications, but is subject to the service standard that all renewal applications must be completed before the expiry of the firm’s current licence.
Stage 4 – Issuance of Licence
Once the assessment phase has been completed the Central Bank will notify the firm of its overall assessment of the application as follows:
(a) Renew Licence – i.e. the Central Bank is satisfied to grant the firm a high cost credit provider's licence based on the information provided in its application submission and will issue a high cost credit provider's licence to the firm; or
(b) Renew Licence with Varied Conditions – i.e. the Central Bank proposes to grant the firm a high cost credit provider's licence but proposes to vary the conditions of the firm’s high cost credit provider's licence. This notification would explain the reason for the proposed variation of the conditions of the licence and the firm will be afforded the opportunity to make written representations in respect of the proposed variation of the conditions of the licence; or
(c) Refusal – i.e. the Central Bank has not been satisfied such that it could issue a licence under (a) or (b) above and it proposes to refuse to grant the firm a high cost credit provider's licence. This notification would explain the reasons for this assessment and the firm will be afforded the opportunity to address these concerns and make written representations in respect of the proposed refusal.