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.
A closer look at FG 21/3 – finalised guidance on transfers
Alistair MacDougall Compliance FCA, Pension, Pension Transfer, PI, transfer
In our recent article giving an overview of Finalised Guidance (FG 21/3), we indicated that we would pick out a few of the more interesting snippets for a closer look. That is not to imply that the rest of the guidance is of no interest, just a reflection that much of the guidance is a […]