Your November update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his November update, including AMI’s Protection Viewpoint, market conditions and future challenges for advisers…

Making the most of AMI Protection Viewpoint findings

AMI’s 2023 Protection Viewpoint report ‘The Perception Gap’ is packed full of findings and insight aimed at mortgage intermediaries…

Consumer Duty – an update

Key Consumer Duty developments and recent communications issued by both AMI and the FCA, with commentary on implications for mortgage intermediary firms…

AR regime – updated AMI Q&A and deadline reminder

Having heard back from the FCA, we have updated AMI’s Q&A documenton the AR regime. We also wanted to remind firms of the upcoming 30 November 2023 deadline…

FCA application window open for firms approving promotions for unauthorised persons

Firms that approve financial promotions for unauthorised persons have until 6th February 2024 to apply for approver permission from the FCA…

FSCS levy and compensation figures update

The FSCS has released an update on its levy and compensation figures for 2023/24, as well as anticipated levy figures for 2024/25…

Edit Content

Log in here for full access to all our great content


Please log in below with your username (which is your email address), using all lower-case letters.


Forgotten your password?
No problem, simply tell us you have forgotten your password to receive instructions instantly via email.

Having problems logging in?
If you are a current member but are unable to login, please first make sure you are using all lower-case letters for your username/email address. If you still have difficulties, please contact us via email at so we can rectify your problem.

Not a member?
Learn more about the benefits of becoming a member or apply online and we will be in touch.

Back in March the FCA communicated six new permission categories relating to debt activity.  Regulatory work has since moved forward with the release of the first draft of how the Senior Managers & Certification Regime (SMCR) will be applied to the rest of the industry, and a more polished version of how the Financial Services Compensation Scheme will be structured from 2018/19.

Whilst these will result in significant changes for firms, it is worth revisiting the impact on consumer credit permissions, despite the fact mortgage brokers should be exempt as such activity is really part of their intermediation.

If firms decided that they carry out debt management activities then they will have had to allocate the compliance oversight function (CF10) to an individual, as well as meeting minimum capital requirements.  Under SMCR, if a firm is already required to nominate a CF10 then they will need to apply the equivalent Senior Management Function.  So with this individual captured under the regime, they will have personal responsibility and accountability for the firm’s compliance.

One of the proposed changes to the FSCS is the extension of its coverage so that claims relating to debt management activities will be eligible. The firms that will contribute to these claims include those with a debt adjusting or debt counselling permission, with the levy based on a firm’s annual debts under management.  This should therefore exclude mortgage intermediaries from contributing to this class.

Firms will need to review the activity they carry out and decide what permissions they should hold.  AMI has issued guidance to member firms which outlines the permissions we believe the majority of mortgage advisers require.  Firms should also consider whether they should be reporting any income relating to consumer credit permissions, as in many cases of consolidating debt into a mortgage contract it is likely to be more appropriate to attribute the income to the mortgage business.

Aileen Lees
Senior Policy Adviser


Forgot Password?

Join Us