FINAL NOTICE

To:

Thinking: Health & Income Ltd

Dated:
7 August 2018

ACTION

1.
For the reasons set out in this Final Notice, the Authority hereby takes the following
action against THIL.



2.
The Authority issued to THIL the Decision Notice which notified THIL that for the
reasons given below and pursuant to section 55J of the Act, the Authority had
decided to cancel THIL’s Part 4A permission.


3.
THIL has not referred the matter to the Tribunal within 28 days of the date on
which the Decision Notice was given to it.


4.
Accordingly, the Authority has today cancelled THIL’s Part 4A permission.

Thinking: Health & Income Ltd 7 August 2018
Final Notice
Page 2

DEFINITIONS

5.
The definitions below are used in this Final Notice:

“the Act” means the Financial Services and Markets Act 2000;

“the Authority” means the Financial Conduct Authority;

“the Decision Notice” means the Decision Notice issued to THIL dated 18 April
2018;

“the Overdue Balance” means the amount owed by THIL to the Authority of
£1,235.23 in respect of periodic fees and levies, which was due for payment by 7
October 2017;

“the Principles” means the Authority’s Principles for Businesses;

“the suitability Threshold Condition” means the threshold condition set out in
paragraph 2E of Schedule 6 to the Act;

“THIL” means Thinking: Health & Income Ltd;


“THIL’s Part 4A permission” means the permission granted by the Authority to THIL

pursuant to Part 4A of the Act;

“the Threshold Conditions” means the threshold conditions set out in Schedule 6

to the Act;

“the Tribunal” means the Upper Tribunal (Tax and Chancery Chamber); and

“the Warning Notice” means the Warning Notice issued to THIL dated 20 March
2018.

REASONS FOR THE ACTION

6.
On the basis of the facts and matters and conclusions described in the Warning
Notice, and in the Decision Notice, it appears to the Authority that THIL is failing to
meet the suitability Threshold Condition, in that the Authority is not satisfied that
THIL is a fit and proper person having regard to all the circumstances, including
whether THIL managed its business in such a way as to ensure that its affairs were
conducted in a sound and prudent manner.


7.
THIL has failed to pay the Overdue Balance and it has not been open and co-
operative in all its dealings with the Authority, in that THIL has failed to respond to
the Authority’s repeated requests for it to pay the Overdue Balance, and has
thereby failed to comply with Principle 11 of the Principles and to satisfy the
Authority that it is ready, willing and organised to comply with the requirements
and standards of the regulatory system.


8.
These failures, which are significant in the context of THIL’s suitability, lead the
Authority to conclude that THIL has failed to manage its business in such a way as
to ensure that its affairs are conducted in a sound and prudent manner, that it is
not a fit and proper person, and that it is therefore failing to satisfy the Threshold
Conditions in relation to the regulated activities for which it was granted a Part 4A
permission.





Thinking: Health & Income Ltd 7 August 2018
Final Notice
Page 3

DECISION MAKER

9.
The decision which gave rise to the obligation to give this Final Notice was made by
the Regulatory Decisions Committee.

IMPORTANT

10.
This Final Notice is given to THIL in accordance with section 390(1) of the Act.

Publicity

11.
The Authority must publish such information about the matter to which this Final
Notice relates as the Authority considers appropriate. The information may be
published in such manner as the Authority considers appropriate. However, the
Authority may not publish information if such publication would, in the opinion of
the Authority, be unfair to THIL or prejudicial to the interest of consumers.


12.
The Authority intends to publish such information about the matter to which this
Final Notice relates as it considers appropriate.

Authority contact

13.
For more information concerning this matter generally, please contact Funmi Ojo at
the Authority (direct line: 020 7066 1354).

Anna Couzens
Enforcement and Market Oversight Division