Lending to someone who can't afford to repay isn't just a credit risk — it's a regulatory breach. Under CONC 5, every consumer credit firm must conduct a reasonable assessment of affordability and creditworthiness before lending. Under Consumer Duty, that obligation is elevated further: firms must now demonstrate not just that they assessed affordability, but that their lending decisions genuinely supported good customer outcomes and avoided foreseeable harm. The FCA's thematic work on consumer credit has been unambiguous — inadequate affordability assessments are one of the most consistent sources of enforcement action in the sector. A properly structured affordability framework from a consultant typically costs £8,000–£15,000.
This template — built by compliance and regulatory experts with over 150 years of combined experience across some of the world's most reputable financial services firms — gives you the same rigour at a fraction of the cost, ready to implement today.
What's included:
Full regulatory mapping: CONC 5 responsible lending obligations, Consumer Duty PRIN 2A, FCA affordability guidance, vulnerability requirements under FG21/1, and credit reference agency search requirements
Multi-layered assessment methodology: income verification (employment, self-employment, benefits, and pensions), expenditure analysis framework, disposable income calculation, and automated assessment tools with manual override protocols
Credit scoring and creditworthiness assessment: CRA searches, credit history analysis, behavioural data assessment, and decision integration with override procedures
Product-specific assessment requirements: personal loans, hire purchase, debt management plans, restructuring and forbearance, refinancing, and high-cost short-term credit
Vulnerability assessment framework: four-driver identification model, reasonable adjustments, decision-making standards for vulnerable customers, and ongoing monitoring procedures
Decision-making governance: approval authority structure, decision rationale documentation, audit trail requirements, and quality assurance review processes
Ready-to-use appendices: Income Verification Template, Expenditure Analysis Checklist, Vulnerability Screening Tool, Decision Record Template, and Affordability Assessment Reference Table + much more
Who is this for?
Compliance Officers, Credit Risk Managers, SMF holders, and operational teams at FCA-regulated consumer credit firms who need a complete, board-approved Affordability and Creditworthiness Assessment Policy that satisfies CONC 5, Consumer Duty, and FCA supervisory expectations simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Lending to someone who can't afford to repay isn't just a credit risk — it's a regulatory breach. Under CONC 5, every consumer credit firm must conduct a reasonable assessment of affordability and creditworthiness before lending. Under Consumer Duty, that obligation is elevated further: firms must now demonstrate not just that they assessed affordability, but that their lending decisions genuinely supported good customer outcomes and avoided foreseeable harm. The FCA's thematic work on consumer credit has been unambiguous — inadequate affordability assessments are one of the most consistent sources of enforcement action in the sector. A properly structured affordability framework from a consultant typically costs £8,000–£15,000.
This template — built by compliance and regulatory experts with over 150 years of combined experience across some of the world's most reputable financial services firms — gives you the same rigour at a fraction of the cost, ready to implement today.
What's included:
Full regulatory mapping: CONC 5 responsible lending obligations, Consumer Duty PRIN 2A, FCA affordability guidance, vulnerability requirements under FG21/1, and credit reference agency search requirements
Multi-layered assessment methodology: income verification (employment, self-employment, benefits, and pensions), expenditure analysis framework, disposable income calculation, and automated assessment tools with manual override protocols
Credit scoring and creditworthiness assessment: CRA searches, credit history analysis, behavioural data assessment, and decision integration with override procedures
Product-specific assessment requirements: personal loans, hire purchase, debt management plans, restructuring and forbearance, refinancing, and high-cost short-term credit
Vulnerability assessment framework: four-driver identification model, reasonable adjustments, decision-making standards for vulnerable customers, and ongoing monitoring procedures
Decision-making governance: approval authority structure, decision rationale documentation, audit trail requirements, and quality assurance review processes
Ready-to-use appendices: Income Verification Template, Expenditure Analysis Checklist, Vulnerability Screening Tool, Decision Record Template, and Affordability Assessment Reference Table + much more
Who is this for?
Compliance Officers, Credit Risk Managers, SMF holders, and operational teams at FCA-regulated consumer credit firms who need a complete, board-approved Affordability and Creditworthiness Assessment Policy that satisfies CONC 5, Consumer Duty, and FCA supervisory expectations simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Image 1 of 9
Image 2 of 9
Image 3 of 9
Image 4 of 9
Image 5 of 9
Image 6 of 9
Image 7 of 9
Image 8 of 9
Image 9 of 9
