Collateral, a Manchester-based peer-to-peer lender, went into administration on April 27. In February 2018, the company, unable to meet its debts as they fell due, purportedly appointed Refresh Recovery as administrator. By law, however, a company carrying out regulated activities requires the consent of the UK Financial Conduct Authority (FCA) to appoint an administrator. The FCA's consent was neither sought nor provided, as the company had historically disputed that it was carrying out a regulated activity. FCA applied for, and obtained, a court order declaring that the initial appointment was invalid and appointing BDO as administrator.