Commentary Consumer credit Section 108: suspension of licences under Part 3 of Consumer Credit Act 1974
623.Section 108 makes a number of amendments to Part 3 of the CCA to provide for the OFT to suspend consumer credit licences. Subsection (3) inserts a new section 32A of the CCA which provides for the OFT to suspend an individual or group licence under the CCA if during the currency of a licence it appears to the OFT to be urgently necessary for the protection of consumers that the licence should cease to have effect immediately or on a specified date. A licence may be suspended for up to 12 months. Subsection (3) also inserts a new section 32B of the CCA which provides that a suspension can last for longer than 12 months if the OFT has given notice that it is minded to revoke the licence either on or before giving the notice of suspension under section 32A or during the suspension period. Subsection (6) inserts a new section 34ZA of the CCA which provides that where a person is invited by the OFT to submit representations in relation to a licence suspension the licence holder will be given 21 days to submit written representations or give notice that he wishes to do this orally.  The OFT is then obliged to reconsider the decision to suspend the licence and make a new determination, and give general notice of that decision once it has been made.  There is no time limit on the OFT for doing this. Subsection (8) amends section 41 of the CCA to insert a new subsection (1ZA). This is in order to make it clear that, where the OFT has reconsidered a decision to suspend a licence (under section 34ZA) and confirmed the suspension, the 28 day appeal period runs from the decision to confirm the suspension.