As Regulatory Compliance Consultants, we provide a support service to both IFAs and stand alone mortgage brokers.
Taking out a mortgage to buy a house is one of the most significant financial transactions that most people ever undertake. Quite properly, the FCA is very keen to protect them. Over the last couple of years, a number of mortgage brokers have been fined, usually for very basic failings which financial services compliance consultants would have picked up.
On 26th April 2014, the changes recommended by the Mortgage Market Review (MMR) came into effect. The most relevant for mortgage intermediaries were:
- The removal of the requirement on intermediaries to assess affordability
- The removal of the non-advised sales process
- Moat interactive sales (e.g. face to face or telephone) to be advised
- Intermediaries must have an ‘execution only’ sales process for non interactive sales (internet and postal)
- Every seller is required to hold a relevant mortgage qualification
- It is no longer compulsory to provide customers with an Initial Disclosure Document (IDD) though firms can continue to do this if they want to. Instead, certain key messages about a firm’s service must be given to customers
- The Key Facts Illustration (KFI) does not have to be given out every time a firm provides the customer with information about a product which is specific to them. Instead it is only required where a firm recommends a product or products, where the customer asks for a KFI, or where the customer has indicated what product they want on an execution only basis
Our specialist mortgage regulatory compliance consultants can set up and monitor systems and processes which ensure compliance with the regulator as well as a high standard of service to clients.
Please contact us for further information.