The changes outlined in the FCA’s Mortgage Market Review come into being on 26th April. This newsletter will act as a reminder to firms of the changes. You should ensure that the updated processes and documents are now implemented.
A brief high level overview of the changes is set out below. Please refer to previous ATEB news articles for more details.
For Intermediaries:
- The non-advised sales process has been removed;
- If there is any interaction between a firm and client then advice must be given, with only very few exceptions;
- Execution only sales can only be carried out for high net worth and professional clients or where the lending is for business purposes;
- The requirement for intermediaries to assess affordability has been removed;
- The compulsory requirement to issue an IDD has been removed from the rules;
- The firm must issue the client with key messages about the firm’s service;
- Key trigger points when a firm has to issue a key facts illustration have been implemented:
For Lenders:
- It is the lenders responsibility to assess affordability;
- Lenders have to verify declared income;
- Interest-only loans can still be granted, but only where there is a credible repayment strategy.
Consumer Duty: It’s a matter of Principle
Huw Reynolds Compliance Conduct, FCA, PI, protection
Apologies for the Consumer Duty overload but unless you’re taking a regulatory sabbatical, this is very much a hot topic. There are in excess of 50 FCA Handbooks (rules and guidance). You cannot be expected to be conversant with all of them, but you should have a good handle on the key ones, such […]