For firms which comply with the requirements under the Conronavirus Business Interruption Loan Scheme (CBILS), the FCA does not expect them to comply with CONC 5.2A.4-34, under which they must carry out a reasonable assessment of a customer’s creditworthiness before taking a regulated lending process forward. 

Firms must, however, continue to carry out creditworthiness assessments in line with the whole of CONC 5.2A on all other regulated lending. 

Individuals under the Senior Managers and Certification Regime (SMCR) in authorised firms who are involved in the CBILS are treated as in compliance with their obligations under COCON 2.1 and 2.2 (with the exception of 2.1.1, 2.1.3 and 2.2.4) with regard to assessments of creditworthiness and affordability.