Aug 19 – A fairer FOS

FOS has now published proposals for its future funding having considered stakeholders’ feedback and the principles FOS has established in its previous conversations. It is proposing to rebalance the levy and case fee to aim for a 50:50 split, with a significantly greater proportion of their income from the FOS levy as opposed to case […]

Aug 19 – Only the headline

Freelance journalist Simon Read brought me sharply to attention when he wrote recently about whether anyone reads newspapers anymore.  The march of on-line and the ability to get anything on Twittersphere, Messenger or Whatsapp has totally changed “communication”.  As Trump continually condemns fake news, the challenge we all face is deciding who is gaslighting who. […]

Jul 19 – The truth that comes from advice

Following the financial crash in 2008, the Mortgage Market Review (MMR) introduced new rules in 2014 which followed a series of connected but distinct consultations that then produced an all-encompassing Policy Statement.  As part of this it is important to recall some of the content of the MMR paper and its rationale: “For some time […]

Jul 19 – SM&CR guides and support

We have produced a suite of documents to assist firms in ensuring they are ready for the new FCA Senior Managers and Certification Regime on 9 December 2019.

Jul 19 – Intermediaries and the SM&CR – what is your culture?

With less than six months before the FCA’s Senior Manager & Certification Regime (SM&CR) is extended across financial services businesses you might think that this is new regulation, based on filling in lots of forms.  Technically in law it is new regulation and there are forms to complete, but for most mortgage advice firms it […]

Jun 19 – The big trapped borrower debate

The issue of the trapped borrower or mortgage prisoner has been on the AMI agenda since the MMR was finalised in 2012.  We could be criticised for not getting enough traction on the issue until late 2018, but we were assured that the Mortgages Market Study was looking at this from our early discussions with […]

Jun 19 – Calling order

In an unprecedented step the FCA has issued a Dear CEO letter to a sector of the market before they have completed the firm authorisation process.  The issues with CMC’s have been expressed by advice firms of all types for many years now, with the capacity of the Ministry of Justice to deal with complaints […]

May 19 – Trapped in a three way tie

The new affordability tests for existing borrowers proposed on FCA CP19/14 will allow lenders to disapply many aspects of the MMR affordability rules which have restricted the options of some borrowers.  It is proposed that the new simpler rules can be applied to any mortgage customer provided they are not borrowing more money.  Lender product […]

May 19 – Slaying the dragons of the MMR

In deciding as part of its Mortgages Market Study that the market needed help by revising advice and selling standards, the FCA has made some interesting statements and assertions.  As one of the few still in their role from the inception of the Mortgage Market Review, I find some of the re-writing of history fascinating.  […]