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PART 1 – The FCA Register of Appointed Representatives



There has been a lot of media focus recently on debt advice sites impersonating debt charities such as StepChange but what about those debt management firms who are listed on the FCA Register? We have previously raised concerns about how the Appointed Representatives (AR) route can potentially be exploited by firms looking for some measure of authentication without being subjected to close regulatory controls, and this issue does not appear to have gone away.


We have previously blogged before how moving into debt advice seems increasingly popular but this article looks at how some debt advice firms are linking with various FCA regulated firms by becoming an AR.



The New AR with a connected past


The Moneycheats project has written numerous blogs which have referred to Matthew Osborn, his directorships (including the CMC, Chadney Smith) and other connections. The last blog, ‘Why consumers looking for debt advice may be getting more” was published in September 2019 and looked at Osborn’s debt advisory firm, Two Financial Services Ltd and its network of Appointed Representatives which enables them to operate in the credit counselling and credit brokerage sectors.


Since then a new AR has been added to the list and this is GSD Media Ltd who trade as Debt Bubble[1].


GSD Media Ltd is run by Robert Smith – another individual who was the subject of our November blog, What do you get when you cross a CMC with an ex-credit-broker and possible lead generator? which looked at Smith’s connections to Nicky Ormerod – the director of the CMC, Savvy Claims Ltd – and also the subject of one of our blogs.


According to the Debt Bubble website they work with FCA regulated brokers and introducers and state they share data with a firm called Clear Introduction Limited help clients optimise their presence on social media.


Companies House report there are 2 firms called ‘Clear Introduction’ – Clear Introduction Ltd[2] which was run by Nicky Ormerod and dissolved in February 2019 and ANS Financial Solutions Limited which renamed itself as Clear Introduction Limited in June 2019[3].


Ormerod had involvement in this company also but it is now run by Stuart Wright although the pair have previously run Key Debt Solutions Ltd[4]and Enigma Leads Ltd[5] together.



The Newly Authorised CMC


It was only a few months ago that the claims management company, The Claims Expert Ltd[6] were given full authorisation by the FCA, but since then 2 of the directors, Martin Supple and Steve Smith have been busy and set up Clear Finance Solutions Ltd[7] last month on 13th January.


What Clear Finance Solutions Ltd do isn’t yet obvious but according to the FCA register[8], the newly formed company is already an Appointed Representative of Superior Insolvency Solutions Ltd (SIS LTD) who are authorised to provide debt counselling and credit broking services and very recently added a trading name of Payless Financial Solutions.


The director of SIS Ltd, Stephen Pritchard[9] also used to own Quality Insolvency Services Ltd[10] (current director is Steve Jennings) and were also an AR of SIS Ltd until last year.


The third director of The Claims Experts Ltd is Vincenzo Vernon and has also been the subject matter in our blog, ex-director of under investigation Direct Financial Claims Ltd appears to have started up a new CMC.



The Credit Broker


Anything Loans Ltd is fully authorised by the FCA and is a credit broker[11] who advertises ‘loans for bad credit’ and ‘payday loans’. Its FCA permissions include entering into a bill of sale loan agreement (often used by logbook lenders) as a lender and entering into high-cost short-term credit as a lender.


Yet this broker/lender has 5 appointed representatives such as Wipe Your Debts Ltd who offer debt solutions[12] and Kahuka Ltd who provide pensions advice[13]. It seems strange that a broker that arranges credit agreements for consumers should have debt solutions firms as ARs.



The Mortgage Broker


Your Mortgage Direct Ltd is fully authorised by the FCA to advise on mortgage contracts and investments, while the debt counselling is limited to ‘counselling – no debt management plans’.[14]

Some of their current Appointed Representatives including Swift Debt Help Ltd are shown below:-




Again, it seems strange that a mortgage broker should have debt solutions firms as ARs.



  1. [1] https://register.fca.org.uk/ShPo_firmdetailsPage?id=0014G00002T4l5TQAR [2] https://beta.companieshouse.gov.uk/company/10953579 [3] https://beta.companieshouse.gov.uk/company/10656448 [4] https://beta.companieshouse.gov.uk/company/08696820/officers [5] https://beta.companieshouse.gov.uk/company/08042161 [6] https://beta.companieshouse.gov.uk/company/11600861/officers [7] https://beta.companieshouse.gov.uk/company/12400856/filing-history [8] https://register.fca.org.uk/ShPo_FirmDetailsPage?id=0014G00002TEeBBQA1 [9] https://www.linkedin.com/in/stephen-pritchard-02639625/?originalSubdomain=uk [10] https://beta.companieshouse.gov.uk/company/09815663/filing-history [11] https://www.anythingloans.co.uk/ [12] https://register.fca.org.uk/ShPo_FirmDetailsPage?id=001b000002NJ5N7AAL [13] https://ifamedia.co.uk/pages/www.planningretirement.co.uk/ [14] https://register.fca.org.uk/ShPo_FirmDetailsPage?id=0010X00004D7lYgQAJ

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