Oct 17 – A proper consultation process
We’re currently going through yet another period of regulatory and legislative changes – the extension of the Senior Managers and Certification Regime (SM&CR), General Data Protection Regulation (GDPR) and the Insurance Distribution Directive (IDD) to name but a few. Notwithstanding firms actually implementing the new requirements, a good process to engage with industry, fully consulting […]
Sept 17 – General Data Protection Regulation
In May we issued a newsflash on the General Data Protection Regulation which comes into effect on 25 May 2018. Firms should be starting to prepare for the changes now.
Sept 17 – Challenging Times
In this first AMI Mortgage Strategy column, I want to look at the key issues facing the modern broker in the post financial crisis but pre-Brexit world. Our market still faces huge uncertainty given the prolonged period of low interest rates which means that almost half of mortgage borrowers have never encountered a rate increase. […]
Sept 17 – Half the answers
Parliament amended FSMA in May 2016 to extend the Senior Managers and Certification Regime to all authorised firms. This emanated from the work previously done by the Parliamentary Commission on Banking Standards, which reported in June 2013, leading to a series of consultations by the PRA and FCA in 2014 and 2015 to capture banks […]
Sept 17 – 50 years without a better robot
Much is being made of the march of technology predicted to make redundant the traditional mortgage broker. Apparently we are soon to see the application of Artificial Intelligence, robo-advice models, enhanced sourcing, propensity modelling and direct to lender application and approval processes which spells the end for traditional approaches. As a child of the 1960s […]
Sept 17 – Ageing population
With the FCA’s report on their ageing population work due this autumn and the ongoing collaboration across the industry on later life lending, it is clear that education and communication is key. Older consumers are seldom aware of their options outside of pensions and residential mortgages. This is not helped by the lack of guidance […]
August 17 – Senior Managers & Certification Regime
The FCA has issued its first consultation on how the Senior Managers Regime, Certification Regime and Conduct Rules will apply to the remaining regulated firms. A second consultation on the technical aspects will be issued later this year.
August 17 – Nailed down
After great deliberation, the FCA is now consulting on “Individual Accountability: Extending the Senior Managers and Certification Regime to all firms”. This new regime will replace the existing Approved Persons regime and moves us from the reality of consumer detriment to the concept of “consumer harm”. It sets out a core regime with a standard […]
August 17 – Still paying for the bad apples
Contributions to the Financial Services Compensation Scheme continue to unfairly dwarf the other elements of firms’ regulatory bills. The invoices received last month reflect the predicted compensation costs for 2017/18. While these may be less than last year’s combined invoice total (July 16 and February 17), firms’ cash flow is being swamped because they will […]
July 17 – Where is our regulator?
The FCA has confirmed regulatory fees for the next year and firms will receive their invoices over the coming weeks. The 10% decrease in the FCA’s periodic fee for mortgage intermediaries is welcomed. However, this was due to the FCA last year over-estimating the work it would be carrying out on the Mortgage Credit Directive. […]
July 17 – The second half
As Brexit now assumes inevitability, we are beginning to see firms that need a European trading hub deciding where they will relocate some core activities. They will delay transfer as long as possible in case deals are agreed, but without unfettered trading access we will see job losses in the UK and adverse impacts on […]
July 17 – Later Life Borrowers
There is a lot of effort going into addressing the issues faced by older consumers, and it is encouraging that the industry is making such positive steps together in this area. It is also very timely considering the FCA’s current focus on the ageing population, with its analysis and recommendations due in September. The recent […]
