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Naomi Seward

Partner

Naomi leads our Retail Finance team and has spent her entire 20+ year career advising within the financial services sector.

She specialises in consumer credit and mortgage regulation and has substantial experience both in private practice and in-house. Her experience includes advising a wide range of consumer finance organisations on remediation activities linked to noncompliance with the Consumer Credit Act, advising on potential breaches of the FCA Conduct of Business Rules, and providing ongoing CCA and regulatory advice to our Consumer Finance clients. 

Naomi also provides substantial perimeter advice to numerous clients seeking to structure their business to avoid the need for authorisation.

She has advised clearing banks, challenger banks, building societies, private and overseas banks, and specialist and main stream credit providers on consumer credit, mortgage and other financial services regulatory issues, and she also has lead on a number of transactional relationships in the sale, purchase, and financing of mortgage and other loan portfolios.

Advising a clearing bank on its first product wide pro-active customer remediation exercise resulting from potential regulatory failings including: identifying start date for remediation, impacted customers, agreeing remediation principles, working with the regulatory liaison team to prepare regulatory updates, drafting customer communications, liaising with the press team as well as working on the go-forward solutions, including improvements in systems, controls, governance and over sight

Assisting a previously unauthorised entity to obtain FCA permission to undertake debt administration including: reviewing and advising on the application process and regulatory compliance of the business, amending the business plan; reviewing and advising on the customer journey; enhancing internal policies including treatment of vulnerable customers, training and competency plans, compliance oversight and risk and governance; as well as responding FCA requests for information

Advising a new entrant on the all aspects of its authorisation, set up and launch of its retail finance business in the UK from advice on the potential type of credit and drafting of the standard form regulated credit agreement and post contractual notices, to providing broader FCA and CONC advice on compliance with the requirements, particularly in relation to affordability and creditworthiness, drafting and reviewing all relevant policies and advising on the regulated business plan.

Retail finance providers such as on all aspects of their running account and fixed sum loan credit propositions from advising on the form and content of regulated documents, to affordability and compliance with the FCA’s Consumer Credit Source book CONC. We also advise them on system changes and impacts of IT development.

Assisting a running account credit provider in its ongoing regulatory engagement relating to the application of persistent debt remedies and issues identified as a consequence of a business model review.

Preparing a regulatory requirements matrix for a consumer credit business against all relevant FCA handbook and Consumer Credit requirements.

Advising numerous mortgage lenders on their terms on conditions, compliance with MCOB requirements and associated FCA permisisons.

As the leader of key workstream within the Financial Services Sector of the firm, Naomi regualarly presents at the Challenger Bank Dinner, at our global client forums, to trade associations such as the Finance and Leasing Association and directly to clients.

Diploma in Legal Practice, Chester Law School 1994-1995

BA (Hons) Law with History, University of Sussex 1991-1994

Naomi Seward

Partner

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