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.



An ATEB reminder for all staff involved in insurance distribution activities
Michael Senior Compliance Conduct, FCA, P1, PI, Security
We thought it appropriate to issue a New Year reminder for firms that have staff … directly involved in the carrying on of the firm’s insurance distribution activities; or within the management structure responsible for the firm’s insurance distribution activities; or responsible for the supervision of a relevant employee acting in the capacity […]