We wished to provide our Members with the facility to pay their Annual sports club subscriptions (<£800) by monthly instalments in order to make membership more affordable in these difficult times.
Our legal advice was that this required us to obtain a Consumer Credit Licence and to register under anti-money laundering regulations. However, other legally authorities are known to hold the view that the situation is not entirely clear cut. Nonetheless, the general advice on CCA is if in doubt, then you should register – so we have.
If we had continued to insist that Subscriptions are paid annually in advance and in full, then niether act applies.
The introduction of the scheme has cost us several thousand pounds in fees, which ultimately has to be borne by the Members of the Club, as it is a non-profit making entity. It has also added significantly to administrative workload and complexity.
The application of both laws to this situation of a self administered scheme (where there is no actual lending of cash) seems well beyond the intention of the legislation and out of proportion to the perceived risks to the idividual and to the state that the Laws are attempting to address. It therefore makes membership of amateur sports clubs such as ours unnecessarily less affordable than they would otherwise be and adds to the Club's unnecessary "red tape".
It is quite possible that the law makers would consider that such self administered annual instalment spreading schemes do already fall outside the respective Laws but no one is prepared to say so uneqivocally (despite lobbying by the National Golf Club Advisory Association).
What's needed is a definite statement that neither Law applies for self administered annual subscription spreading schemes of this type, where no actual cash loan is involved.
Why is this idea important?
By making membership of amateur sports clubs less costly and more affordable, it will hopefully encourage more people to participate in healthy recreational activities. (It is worth noting that these are the same objectives as those of the current CASC regulations.)
Unequivocal removal of the need to operate unnecessarily under the CCA/Money Laundering regulations will also reduce the Club's burden of "Red Tape".