Dan Jones

Partner, Orrick, Herrington & Sutcliffe

With a strong focus on the fintech sector, Dan advises some of the world's leading financial services firms on all aspects of their UK and European regulatory obligations.

Dan has experience across the full spectrum and life cycle of financial services firms: from determining whether the firm's products or services are the subject of financial services regulation, assistance in obtaining a regulatory license, interpretation of applicable regulations and implementation guidance through to M&A regulatory due diligence and skilled person's reports in the event of regulatory investigation.

His clients include global retail and investment banks, asset managers, e-money issuers and payments services providers, crypto-asset issuers, wallets and exchanges.

Dan's notable work includes advice to the UK Open Banking implementation body, the development of a digital only retail bank for a U.S. headquartered global bank and preparing the regulatory license application for a leading global payment services provider.

Before joining Orrick, Dan spent more than a decade working in UK ‘magic circle’ law and ‘Big 4’ consulting firms, advising leading fintech's on regulatory issues across the UK, Europe and the Middle East.

Contributed to

8

Consumer credit agreements—pre-contract requirements

Practice Notes

This Practice Note examines pre-contract disclosure in consumer credit agreements under the disclosure regulations made under section 55 of the Consumer Credit Act 1974 (CCA 1974), together with regulatory requirements encapsulated in Chapter 4 of the FCA’s Sourcebook on Consumer Credit (CONC 4).

Financial Services

Consumer credit—loans to employees and directors and employee share schemes

Practice Notes

This Practice Note examines the circumstances under which loans to employees or directors and employee share schemes may fall within the scope of the UK consumer credit regime and the implications for a firm if its arrangements are not exempt.

Financial Services

Exempt consumer credit agreements under the FSMA 2000 (Regulated Activities) Order 2001

Practice Notes

This Practice Note seeks to explain the types of agreements which will be exempt agreements under the FCA’s consumer credit regime. This Practice Note also provides an overview of exempt consumer hire agreements and exempt agreements entered into by local authorities.

Financial Services

Operating an electronic system in relation to consumer lending

Practice Notes

This Practice Note examines the regulated activity of operating an electronic system in relation to consumer lending, including the main elements of operating an electronic system in relation to lending, the rules applicable to firms authorised to operate an electronic system in relation to lending and relevant exclusions from the regulated activity.

Financial Services

Regulated activities relating to the provision of credit information services and credit references

Practice Notes

This Practice Note provides an overview of the regulated activities of providing credit information services and providing credit references under articles 89A and 89B of the Financial Services and Markets Act (Regulated Activities) Order 2001, SI 2001/544 (RAO). It examines what constitutes these regulated activities, any relevant exemptions and exclusions, the FCA’s conduct of business rules which apply to credit information services firms and the FCA’s current strategy for CRAs and CISPs.

Financial Services

Regulated activities—credit broker

Practice Notes

This Practice Note provides an overview of the main elements of the regulated activity of credit broking under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO), SI 2001/544 including the activities which constitute credit broking under the RAO, relevant exclusions and the FCA rules which apply to credit brokers.

Financial Services

Responsible lending requirements—CONC 5

Practice Notes

This Practice Note looks at the Financial Conduct Authority’s (FCA) Consumer Credit Sourcebook (CONC) chapter 5 (CONC 5) concerning rules and guidance on responsible lending requirements, including the requirement to conduct a creditworthiness assessment before entering into an agreement and conduct of business in relation to credit brokering.

Financial Services

Restrictions on varying or modifying consumer credit agreements

Practice Notes

This Practice Note examines the restrictions placed upon authorised firms when varying consumer credit agreements. It discusses the restrictions on varying consumer credit agreements, how a party to a regulated agreement can vary an agreement at its own discretion (unilateral), the relevant rules relating to modifying agreements and the practical issues that firms need to consider.

Financial Services