The BBA is generally supportive of the Government’s approach to the transfer of consumer credit regulation to the FCA – as set out in the HM Treasury/BIS and FSA consultation papers. Although our long-standing preference was to see the FCA assume regulatory responsibility for a modified Consumer Credit Act (“Act”) without the need for supplementary FSMA rules and principles, we believe that in the absence of such an approach the Government’s proposals are mostly pragmatic, proportionate and achievable – although the timetable for implementation is hugely challenging. . .

http://www.bba.org.uk/media/article/bba-submission-to-hmt-credit-regulation-cp