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.



Abridged advice – how is it going so far?
Alistair MacDougall Compliance 2015, 2018, 2020, 2021, abridged, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
Based on data and live visits to firms during the period from April 2015 to rule changes in 2018 and 2020, the FCA believed that far too high a proportion of clients were being recommended to transfer safeguarded benefits. This was predicated on the longstanding rule which stated: “… a firm should start by assuming […]