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The FCA mortgages market study in its interim report calls for four substantive changes to improve the market for consumers.  In calling for a tool to help find a broker and one to allow consumers to have an enhanced price comparison site which incorporates more lender criteria and affordability, these cut across a number of commercial providers in the market place.

Trade bodies are being asked to work with the FCA to develop these initiatives.  Having started to look at who we might have to work with and the options in how we engineer such innovation, I am wondering if this might in itself be anti-competitive.  In both these areas there are already commercial firms operating and others looking to develop solutions, some of whom are member firms.

The review has identified that these are tools to assist consumers in selecting a broker where they feel they need help, but could also allow consumers to go direct to lenders on an execution only basis to obtain their mortgage, remortgage or product transfer.  These developments merit wide debate across our industry and the interim paper and its supporting raft of occasional papers deserve careful and detailed scrutiny.  In one aspect of the data analysis upon which the recommendations are based, only 2 year fixed rate cases on mortgages that completed between January 2014 and June 2016 are considered.  A fascinating foundation upon which to build a new approach to our market.

Lenders and brokers need to have a long hard look at our future.

Robert Sinclair
June 2018

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