Your February update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his February update, discussing the latest issues in the industry and how we can tackle them…

Tackling barriers: The Protection Gap

AMI Senior Policy Adviser Stacy Penn discusses the Perception Gap in the protection market, in this article originally published in Moneyfacts…

The FCA in the insurance space – a more assertive regulator?

Following introduction of Consumer Duty, we have seen signs the FCA is shifting towards becoming a more assertive regulator…

The Perception Gap

AMI Senior Policy Adviser Stacy Penn discusses the findings from AMI’s latest Protection Viewpoint – The Perception Gap, in this article written for TMA Club…

Consumer Duty: The next steps – what does 2024 have in store?

On 6th December 2023, the FCA hosted a webinar titled Consumer Duty: The next steps – we draw out the key points of relevance to mortgage intermediary firms…

Your January update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his January update, reflecting on the challenges and opportunities of the year ahead…

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.

The Dear CEO letter to second charge lenders made fascinating reading.  Not the minor errors by one lender referred to by some commentators in the lead-up to its publication. The FCA has significant concerns, found poor practices and fears that lenders may not be lending responsibly.

They found disposable income figures in applications which were inconsistent with the amount of unsecured debt the applicant was carrying.  Generally the review of the reality of income and expenditure was not robust and challenge not sufficiently applied.  Also the application of stress testing was inconsistent and not recorded adequately in policies or individual case files.

The affirmation of the income for self-employed applicants also lacked rigour. The FCA expects use of the tax calculation and a tax year overview documents from the HMRC website rather than accountant prepared assurances.  Also where a lender uses ONS or other data to check expenditure it should be applied to assess credibility; be at a current and realistic levels; and not as a substitute for the real situation of the applicant.

In the world of seconds, the broker is more involved in the underwriting and application process as well as completion activity.  Lenders need to ensure they have appropriate controls over this and brokers’ management will need good systems of oversight, checking and monitoring to ensure that applicants get the right outcome.

The whole second charge sector will need to review its practices and ensure it is compliant.  Expect change in the next three months.

Robert Sinclair
March 2018


Forgot Password?

Join Us