On 13 April 2021, the UK Financial Conduct Authority published a webpage reminding consumer credit firms that:
– Brexit changes to pre-contractual information (a final ‘au revoir’ to the SECCI and ECCI!); and
– information for firms subject to CONC 2.7.2R(4)(a),
must be implemented by 31 May 2021.
The end of the transitional provisions mean the post-Brexit disclosures must be used from 1 June 2021.
If pre-contractual information (formerly the SECCI or ECCI) disclosed under Section 55(1) of the Consumer Credit Act 1974 is non-compliant then the agreement is unenforceable without the Court’s permission (see Sections 55(2) and Section 127(1)(za) of the Consumer Credit Act 1974).