Log in here for full access to all our great content

As you will hopefully have seen, we have published our initial thoughts on the FCA’s new Consumer Duty policy. In keeping with other major changes, we will try to deliver our thinking to you in bite sized chunks. This should allow you to plan appropriately, limit confusion and give you the best chance of meeting the requirements and deadlines. In the coming weeks we will begin to run workshops and deliver more detailed information. These will, hopefully, allow you to reach next July in the best possible position.

As we lean into these significant changes, we are also all dealing with cost of living challenges. The FCA has set out its thinking in a Dear CEO letter to lenders. This makes it clear that firms should consider carefully the real needs of consumers, not just a debt restructuring solution. All advisers must consider whether proper debt advice is required before a debt consolidation solution is explored. This is particularly the case in the second charge market and in lifetime mortgages. The FCA has highlighted that full assessments of circumstances and income and expenditure analysis is expected. The FCA will be reviewing cases to establish that recommendations made are suitable not just for the short term but also work long term.

Finally, I am aware that the mortgage world has rarely been as difficult as now. Extended pipelines, processing delays, escalating interest rates and sudden withdrawal of products. I know how frustrating this is as you try to get the best possible deal for your customer. I would just ask that you deal sympathetically with people you are dealing with at lenders, valuers and conveyancers. It is seldom that the person you are talking to has made the decisions that are impacting you or your customer. They are trying to do their best the same way you are. Please treat them with respect.
Please keep safe, enjoy what remains of the summer, and be ready to help all those that will undoubtedly ask us for help as we face into the challenges that will escalate as we progress through the end of this year and into 2023.