Frances Hodgkins
Frances is a Managing Associate in the Financial Regulation Group. She is experienced in advising a broad range of clients including retail banks, private equity investment houses, payment services firms and electronic money issuers on a mixture of transactional, advisory and contentious matters.
Frances works with clients on a wide spectrum of topics, and has particular experience advising on authorisation applications, perimeter and supervisory matters, and conduct of business requirements.
Frances has also advised on a number of regulatory change projects, including in relation to the implementation of the Second Payment Services Directive (PSD2) and forthcoming changes in the consumer finance space (in particular, in relation to buy-now-pay-later). She has gained significant first hand, practical experience of advising on (and assisting with the management of) such regulatory change projects having spent time on secondment to a large international bank’s regulatory change team and, prior to joining Linklaters, spending a number of years working in-house in a variety of roles at Visa Europe.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2016
Experience
- Visa Europe (February 2011 - March 2017)
Qualification
- LPC (2015)
Education
- King’s College London, Post Graduate Diploma in EU Competition Law (2016 – 2017)
- The University of Law, LPC (2014 – 2015)
- The University of Buckingham, LLB Law (Hons) (2005 - 2007)
1 Contributions by Frances Hodgkins
PRACTICE NOTES
FCA Consumer Duty (UK) for Payments and e-money Firms: Scope, Distribution Chains, Cross-cutting Rules, Four Outcomes, and 2024-2025 Supervisory Findings
This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for payments and electronic money (or e-money) firms
For the purposes of this Practice Note, a payments firm is used as a broad term for a ‘payment service provider’ (PSP) under the Payment Services Regulations 2017, SI 2017/752 (PSRs 2017).
Authorised payment institutions
Small payment institutions
Registered account information service providers
References to an e-money firm mean entities within the Electronic Money Regulations 2011, SI 2011/99 (EMRs 2011).
Authorised electronic money institutions
Small electronic money institutions
In broad terms, the Consumer Duty (the Duty) captures firms undertaking regulated activities in the UK that fall within the FCA’s scope. Some payment and e-money firms will deal directly with retail customers, while others participate indirectly through a distribution chain that reaches a retail end user. The Duty extends to both scenarios; however, the degree to which it bites depends on whether the firm sets, or has a material influence over, outcomes for retail customers. This Practice Note examines the scoping assessment for payment and e-money firms, including...
Financial Services
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