Under the changes to the Mortgage Credit Directive (MCD) if you want to describe your firm as an Independent Mortgage Intermediary after the implementation of MCD, you will need to demonstrate that you consider second charge lending as well as first charge.
A new rule, MCOB 4.4A.4R (3), states
- An MCD mortgage credit intermediary must only disclose that it is independent if its consideration of MCD regulated mortgage contracts across the market is unlimited.
MCD regulated mortgage contracts includes second charge lending.
You may already have received an MCD data collection questionnaire from the FCA or will receive one shortly. You will need to complete this using the FCA Connect system.
One of the questions will ask if you intend to ‘do second charge mortgage business.’ As stated above, to use the term ’independent’ you will need to consider second charge loans as an option. To be independent your client files will need to evidence that second charge was considered and recommended if most suitable for the client.
This applies to mortgage business only. The current independence rules for investment business remain unchanged.
Regulatory Change – Proposed Changes to the Normal Minimum Pension Age
David Anderson Suitability 2021, Conduct, NMPA, normal minimum pension age, Pension, protected, protection, transfer, Update
We have made a change to ATEB Suitability following a recent regulatory development. What does this mean for me? Following the Draft Finance Bill published on 20 July 2021, we have updated the wording of our ‘Proposed changes to Normal Minimum Pension Age (NMPA)’ section within the ‘Retirement Advice’ page of the main […]