Unregulated Activity Statement

Commercial Debt Recovery & Payment Collection Arrangements

Credvanta Recovery Group Limited (“Credvanta”) is a company incorporated and registered in England and Wales under company number 17251971, with its registered office at:

5 Canon Court
Institute Street
Bolton
BL1 1PZ
England

For all operational, trading and correspondence purposes, Credvanta conducts business from:
Credvanta Recovery Group Limited
Suite 2/3
48 West George Street
Glasgow
G2 1BP

References in this Statement to “Credvanta”, “we”, “us” or “our” mean Credvanta Recovery Group Limited.

1. Our Business

Credvanta provides commercial business-to-business (B2B) debt recovery services throughout the United Kingdom.

Our services include, where appropriate:

• Pre-legal commercial debt recovery;
• Letters Before Action;
• Telephone, email, SMS and written recovery communications;
• AI-assisted communications;
• Negotiation of repayment arrangements;
• Trace and locate services;
• Commercial field visit services;
• Recovery of statutory interest and compensation where legally recoverable; and
• Referral of matters to independent third-party legal representatives where instructed by the Client.

Credvanta acts solely as a commercial debt recovery and collection agent on behalf of its Clients.

2. Regulatory Status

Credvanta undertakes commercial business-to-business (B2B) debt recovery activities only.

Credvanta does not undertake any regulated activity.

In particular, Credvanta does not undertake:

• regulated consumer credit activities;
• regulated commercial credit activities;
• debt counselling;
• debt adjusting;
• debt administration;
• legal services;
• insolvency services;
• banking activities;
• deposit-taking activities;
• investment services;
• insurance distribution activities;
• electronic money issuance;
• payment institution services;
• money remittance services; or
• any other activity requiring authorisation or regulation by the Financial Conduct Authority or any other UK financial regulator.

Credvanta is not authorised or regulated by the Financial Conduct Authority (FCA).

Credvanta’s services are limited exclusively to the provision of unregulated commercial business-to-business debt recovery and related administrative services carried out under contractual authority granted by its Clients.

Credvanta’s payment collection, reconciliation and settlement arrangements form an integral part of its commercial debt recovery service and are undertaken solely in accordance with the contractual authority granted by its Clients under the Service Agreement, Terms & Conditions and Client Service Acceptance & Authorisation.

On the basis of Credvanta’s business model and the services it provides, Credvanta does not consider its activities to constitute regulated payment services under the Payment Services Regulations 2017.

Nothing in this Statement constitutes legal advice or should be interpreted as representing that Credvanta provides regulated financial services or any activity requiring FCA authorisation.

3. Authority to Collect Payments

Clients expressly authorise Credvanta, through the Service Agreement, Terms & Conditions and Client Service Acceptance & Authorisation, to collect and administer payments received from Debtors in connection with instructed commercial debt recovery matters.

Credvanta receives and administers recovered monies solely in its capacity as the Client’s authorised commercial debt recovery and collection agent.

Payment made by a Debtor to Credvanta in accordance with the contractual arrangements between Credvanta and the Client constitutes payment received by Credvanta on behalf of the Client.

Credvanta does not obtain any beneficial ownership of monies recovered on behalf of its Clients, except to the extent of its contractual entitlement to commissions, fees, disbursements and any other sums properly due under the applicable agreements.

4. Payment Collection Arrangements

To facilitate the efficient recovery of commercial debts, Credvanta utilises payment methods, merchant acquiring facilities and payment processing services operated or arranged by Credvanta.

Recovered monies are received into Credvanta’s undesignated Client Money Account solely for the purposes of:

• receiving debtor payments;
• identifying and allocating payments to the appropriate Client;
• reconciling receipts received from payment providers and banking partners;
• maintaining appropriate accounting records;
• deducting commissions, agreed fees, disbursements, the minimum monthly usage fee where applicable and any other contractual sums due to Credvanta; and
• remitting the Net Recovery to the Client in accordance with the applicable contractual documentation.

Credvanta receives and administers recovered monies solely in its capacity as the Client’s authorised commercial debt recovery and collection agent.

5. Client Money Account

Recovered monies are received into Credvanta’s undesignated Client Money Account.

The Client Money Account is operated solely for the administration, reconciliation and onward distribution of monies recovered on behalf of Clients.

Credvanta maintains appropriate accounting records in respect of all monies received, reconciled, deducted and remitted.

Recovered monies are reconciled and administered strictly in accordance with Credvanta’s published Terms & Conditions.

Credvanta is not required to segregate monies recovered for individual Clients within the Client Money Account, provided that accurate accounting records are maintained and each Client’s entitlement can be identified through Credvanta’s reconciliation records.

6. Reconciliation & Settlement

Unless otherwise agreed in writing, recovered monies are reconciled on a weekly basis.

Credvanta ordinarily issues each Sunday a Reconciliation Statement comprising:

• a Credit Note recording the gross amount recovered on behalf of the Client; and
• a VAT Invoice detailing commissions, fees and other contractual deductions.

Following reconciliation, Credvanta ordinarily remits the Net Recovery to the Client within five (5) to seven (7) working days, subject to banking times, payment processor settlement cycles, fraud prevention procedures, compliance requirements, chargebacks, disputes or circumstances beyond Credvanta’s reasonable control.

Where authorised under the contractual documentation, Credvanta may deduct:

• recovery commissions;
• fixed recovery fees;
• field visit fees;
• trace fees;
• agreed legal costs and disbursements;
• the minimum monthly usage fee where applicable;
• outstanding invoices; and
• any other sums contractually due,

before remitting the remaining Net Recovery to the Client.

7. Transparency

Credvanta is committed to operating a transparent commercial debt recovery service.

Before services commence, Clients are provided with contractual documentation explaining:

• the authority granted to Credvanta;
• payment collection procedures;
• operation of the Client Money Account;
• reconciliation procedures;
• settlement arrangements;
• commissions, fees and charges;
• contractual rights of deduction and set-off; and
• the responsibilities of both parties.

These documents form the contractual basis upon which Credvanta provides its services.

8. Limitation of Services

Credvanta’s role is limited to commercial debt recovery and related administrative services.

Credvanta does not:

• determine disputed contractual liability;
• determine the legal validity of debts;
• provide legal representation;
• exercise enforcement powers;
• act as sheriff officers, certificated enforcement agents or bailiffs;
• provide regulated debt advice;
• provide financial advice;
• provide insolvency advice; or
• provide consumer credit services.

Where legal proceedings, enforcement action or other legal services are required, Credvanta may, with the Client’s prior authority, instruct one of Credvanta’s trusted independent partner law firms on the Client’s behalf. The appointed law firm shall provide all legal services in connection with the recovery of the Client’s debt. Credvanta may continue to liaise with both the Client and the appointed law firm for administrative, communication and case management purposes. Any legal costs, disbursements, counsel’s fees, court fees or other third-party legal expenses incurred in connection with the instruction may be recharged to the Client, together with any agreed administration fee or markup, in accordance with the Service Agreement and Terms & Conditions. Credvanta does not provide legal advice or undertake reserved legal activities, all of which are carried out solely by the appointed law firm.

9. Governing Documents

This Statement should be read together with:

• Credvanta Recovery Group Service Agreement;
• Credvanta Recovery Group Terms & Conditions;
• Client Service Acceptance & Authorisation;
• Data Protection & Privacy Policy;
• Complaints Handling Procedure;
• Vulnerable Person / Business Policy;
• Anti-Money Laundering (AML), Financial Crime, Sanctions & Client Money Handling Policy; and
• any other operational or compliance policies published by Credvanta from time to time.

In the event of any inconsistency between this Statement and the Service Agreement or Terms & Conditions, the Service Agreement and Terms & Conditions shall prevail.

10. Contact

Credvanta Recovery Group Limited
Suite 2/3
48 West George Street
Glasgow
G2 1BP

Email: Compliance@credvanta.co.uk
Telephone: 0800 975 7066