Circlworld

Lending — Jurisdiction Disclosures

Version v1.0 · Effective pending · Last updated 2026-06-03

Jurisdiction Disclosures

Status: v0.1 draft. The UK and Jamaica addenda below are skeletal placeholders identifying the regulatory regimes and the specific statutory hooks that the activated version of each addendum will reference. Counsel review is required per jurisdiction.

United Kingdom

The circle's / federation's own co-operative legal form in the United Kingdom — its own member-constituted collective vehicle, not a separate or third-party entity — will be registered as a credit union under the Credit Unions Act 1979 or as a co-operative society under the Co-operative and Community Benefit Societies Act 2014, operating under FCA Part 4A permission for credit-related regulated activities. A separate UK bank or credit union may be appointed as account provider / custodian only for the dedicated multi-signature lending account and is never the lender.

2. Applicable consumer-credit regime

The lending is governed by:

  • The Consumer Credit Act 1974 (as amended).
  • The FCA Handbook, specifically:
    • CONC 4.2 (pre-contract disclosure — the PCCI),
    • CONC 5 (creditworthiness and affordability assessment — the "appropriate test"),
    • CONC 7 (arrears, default, and recovery, including guarantor protections),
    • CONC 11 (cancellation rights, including the 14-day withdrawal period under CCA 1974 s.66A).
  • The Financial Services and Markets Act 2000 (FSMA) general permission framework.

3. Pre-contract disclosure

The PCCI template at /legal/lending-pcci is specialised into the UK CONC 4.2 PCCI form. The specialised form is the statutory document for UK loans.

4. Cancellation rights

UK borrowers have a 14-day right of withdrawal under CCA 1974 s.66A, mirrored in the Member Borrowing Agreement §3.

5. Guarantor protections

UK guarantors are protected by FCA CONC 7 specific rules, including:

  • A clear warning, given before consent, that the guarantor may be required to repay in full.
  • A "time to consider" period before consent is binding.
  • Restrictions on use of Continuous Payment Authority against guarantors.
  • Specific call procedures with notice and reasonableness duties.

The Guarantor Terms §§ 1–10 are tightened to conform; UK guarantors see the CONC-conforming version.

6. Dispute pathway escalation

The small-claims threshold above which UK lending disputes may escalate to court is £10,000 (CPR Part 27). Below the threshold, Stages 1–3 of the Lending Dispute Pathway must be completed before court.

7. Ombuds and external redress

UK borrowers may bring an unresolved complaint to the Financial Ombudsman Service (FOS) in addition to or instead of the platform's Stage 3 Decision Room. The FOS may make binding decisions up to £415,000 (subject to current limits).

8. Data protection

UK lending data is processed under the UK GDPR and the Data Protection Act 2018. The Privacy Policy §§ on lending apply.

9. Credit reference reporting

Where a default is reported to UK credit reference agencies, the borrower is notified in advance per ICO guidance. The Financial Reliability Record is a parallel internal record; the credit-reference-agency report is a separate matter governed by the Principles of Reciprocity.

10. Insolvency

UK Lender insolvency proceeds under the credit-union or co-operative resolution rules supervised by the Bank of England and the FCA. The Financial Services Compensation Scheme (FSCS) provides no protection for cooperative-lending stakes (these are not deposits); FSCS may apply to specific deposit-like elements only.

Jamaica

The circle's / federation's own co-operative legal form in Jamaica — its own member-constituted collective vehicle, not a separate or third-party entity — will be registered as a credit union under the Co-operative Societies Act, regulated by the Department of Co-operatives and Friendly Societies (DCFS) and the Bank of Jamaica (BoJ) under the Credit Union Act regime. A separate Jamaican deposit-taking institution may be appointed as account provider / custodian only for the dedicated multi-signature lending account and is never the lender.

2. Applicable consumer-credit regime

The lending is governed by:

  • The Co-operative Societies Act.
  • The Money Lending Act (where applicable).
  • The Fair Competition Act and Consumer Protection Act.
  • The Microcredit Act, 2020 for microcredit-sized lending (J$ thresholds apply).
  • The Banking Services Act, 2014 to the extent the circle's / federation's own co-operative form carries on banking-services activity.

3. Pre-contract disclosure

The PCCI template at /legal/lending-pcci is specialised into a Jamaica-conforming pre-contract disclosure, signed before disbursement.

4. Cancellation rights

Jamaican consumer-credit cancellation rights are jurisdiction-specific; the Member Borrowing Agreement §3 is conformed to the applicable rule on activation.

5. Guarantor protections

The Guarantor Terms §§ 1–10 are specialised to Jamaican co-operative-society guarantor rules.

6. Dispute pathway escalation

The small-claims threshold above which Jamaican lending disputes may escalate to court is J$1,000,000 (Resident Magistrate's Court). Below the threshold, Stages 1–3 of the Lending Dispute Pathway must be completed before court.

7. External redress

Jamaican borrowers may approach the Consumer Affairs Commission for non-binding redress, in addition to or instead of the platform's Stage 3 Decision Room.

8. Data protection

Jamaican lending data is processed under the Data Protection Act, 2020, supervised by the Information Commissioner.

9. Currency

Jamaican loans are denominated in Jamaican dollars (JMD). Multi-currency loans are not offered.

10. Insolvency

Jamaican Lender insolvency proceeds under the Co-operative Societies Act resolution regime, supervised by DCFS.

Cross-jurisdiction note

Cross-jurisdiction unsecured lending is not offered. The Lending Center is jurisdiction-bounded by design — every pool, every loan, every funder is in one jurisdiction. A Member living in the UK does not borrow from the Jamaica vehicle, and vice versa.

Members holding circle memberships across jurisdictions may join multiple pools, each in their own jurisdiction's vehicle. Each pool is bounded; cross-pool transactions are not lending.

Future jurisdictions

The next jurisdictions on the roadmap (subject to Member demand and counsel scoping) include:

  • United States — state-by-state cooperative-credit or community-development-financial-institution (CDFI) structure.
  • Canada — provincial credit-union regulation (varies by province).
  • Kenya — SACCO regulation under the Co-operatives Act and the SACCO Societies Act, supervised by the SACCO Societies Regulatory Authority (SASRA).

Each new jurisdiction requires the corresponding addendum here, the vehicle registration, and counsel sign-off before any pool in that jurisdiction goes live.

Reminder: v0.1 draft. The UK and Jamaica addenda are placeholders identifying the regimes. Activation-grade versions will be issued per jurisdiction once counsel signs off and the vehicle is registered.