Key Consumer Duty developments and recent communications issued by both AMI and the FCA, with commentary on implications for mortgage intermediary firms…
As we come to the end of another year, it is appropriate to reflect on another great period for intermediaries. We have continued to deliver great support and service for UK consumers who are looking for a mortgage to support their desire to buy their house to build a home. Despite the irrational findings by the FCA that many might have got a cheaper deal, the industry knows that our customers got the right deal for them. There are many reasons why the cheapest deal is not always the most appropriate, a basic fact lost on those who undertook the Mortgages Market Study. AMI is still talking to the FCA to help them understand this and ensure that any remedies they bring to market are appropriate and proportionate.
In doing this we are working closely with other trade bodies. UK Finance, IMLA and the BSA, who are all united with us in challenging much of the thinking and solutions being considered. This is the first time in my dozen years representing intermediaries that I have seen as much consistency in the views across the three main lender and broker trade bodies. This consistency must make the FCA consider its currently adopted positions carefully.
2018 has been another good year with purchase and remortgaging activity likely to total slightly in excess of £270bn, of which more than 70% will be completed by intermediaries. In addition, with the product transfer market now exceeding £150bn, it is estimated that about a third of this is now being done by brokers. This is a great foundation on which to build great protection advice and invest in technology to safeguard the future of advice and firms.
We need technology to allow the consumer to interact with us more effectively and to reduce the amount of administration each case takes. We need to secure time for the adviser to speak to consumers about the issues important to them, not gathering data and answering queries. Moving information and data to lenders, insurers, conveyancers and valuers seamlessly is the future, with consumers also having access to track all aspects of their transaction.
Finally, I am aware that many firms are receiving data subject access requests mainly from one particular source. These are usually followed by pre-action protocol letters, but we are not seeing the usual complaint to the firm or referrals to the ombudsman service. It looks as though these are being held in waiting for some form of “blitz” of legal and court activity. If any broker firm is in receipt of such subject access requests, they should advise their PI insurer as soon as possible. They should also take care that the names, address, any dates of birth and authorities are complete and accurate. Firms need to ensure they are dealing with the correct cases to meet their GDPR requirements.