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.



Suitability Reports: Who is Fred?
David Anderson Suitability complaints, Pension, PI, Update
There is an old joke about a man going to his dentist, picking up a magazine in the waiting room and reading that the Titanic had sunk. This reference to how out of date dentists’ reading material can be is unfortunately not merely a mildly amusing joke or restricted to dentists.