Blue Panda Finance Ltd

Limits on what they may do

• Restriction on regulated activities

  1. The Firm must not, without the prior written consent of the Authority: i. accept or onboard any new client for the provision of a regulated claims management service; ii. enter into any agreement with a new client to provide a regulated claims management service; or iii. permit any person acting on its behalf, including through any trading name, introducer or lead-generation arrangement, to undertake the activities described in paragraphs 1(i) or 1(ii). iv. For the avoidance of doubt, Paragraphs 1 i, ii and iii do not prevent the Firm from continuing to provide services to clients with whom it entered into an agreement before the Requirement took effect, or from progressing claims already being handled for those clients, subject to the Firm continuing to comply with all applicable regulatory requirements. v. For the purposes of this Requirement: a. “new client” means a person with whom the Firm had not entered into an agreement to provide a regulated claims management service before the Requirement took effect; and b. “regulated claims management service” means a service falling within the regulated claims management activities covered by the Firm’s Part 4A permission. 2. The Firm must, within 24 hours of the Effective Date, withdraw all active financial promotions (including, but not limited to, financial promotions on its website, social media content, Google adverts and digital display videos). For the avoidance of doubt this should include the Identified Financial Promotions. The Firm must notify the Authority once this has been complied with. 3. The Firm must not, without the prior written consent of the Authority, publish any new financial promotions. 4. The Firm must provide a report to the Authority detailing, in the format specified in Annex 3, the number of financial promotions withdrawn or amended in accordance with paragraph 2 above within two weeks of the Effective Date. 5. The Firm must procure the completion of the independent external review of its systems and controls, policies and procedures relating to financial promotions referred to in its correspondence with the Authority. The Firm must provide the Authority with the final, unredacted review report within 7 working days of receiving it, together with: (a) the review’s terms of reference, scope and methodology; (b) all findings and recommendations; (c) the Firm’s management response; (d) its remediation plan, including responsible owners and target dates; and (e) evidence of any remediation already completed. The Firm must notify the Authority promptly of any material change to the review’s scope, timing or reviewer. 6. Following the review as set out at point 5 above, the Firm must provide a report to the Authority detailing the outcome of the actions it has taken within six weeks of the Effective Date. The report should contain feedback and recommendations regarding the Firm’s systems and controls in relation to its financial promotions.