FCA Consultation on Fees & Levies for 2024/25

Members may have seen that the FCA issued their annual consultation on the fees charged to firms on Tuesday 9th March – AMI comments…

Consumer Duty has made vulnerability about ‘characteristics’ rather than ‘binary’

Chloe Timperley’s comments from the British Specialist Lending Senate 2024 regulatory expectations around vulnerability…

Your March update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his March update, including the Mortgage Charter and the FCA annual business plan…

Sexism in the City feedback: recommendations for firms

The feedback report for the September Sexism in the City paper has been released. We are cited in the report, relating to our event code of conduct…

AI will not replace ‘divergent or creative’ thinking

Chloe Timperley’s comments from the British Specialist Lending Senate 2024 on generative AI and regulatory expectations around vulnerability…

Mortgage Brokers: The climate is changing, should you?

The Mortgage Climate Action Group (MCAG) is delighted to invite you to its upcoming webinar: ‘The Climate is Changing, Should You?’ on 18th March at 10am…

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With the deadline for the General Data Protection Regulation now just six months away, we still have the ICO finalising guidance whilst the Data Protection Bill is still making its way through Parliament. Not to mention the new Privacy Regulation which is supposed to be implemented at the same time, yet it’s still being agreed by the European Council and Parliament. So is this going to be catastrophic for firms, or is there an element of scaremongering here?

If firms are already compliant with the Data Protection Act, the updates to processes and documentation will be easier to implement. Knowing where your data is held, how it is held (security being the main concern) and by whom are key starting points. If you don’t use customer data for marketing, then again this will narrow down your to-do list.

One focus should be the data relationship with lenders. We need to agree a consensus with lenders to ensure that everyone understands their responsibilities. For example if a broker is collecting data on behalf of the lender in order for it to assess affordability, should it be the broker’s responsibility to keep payslips for two years after the offer has been issued? For what purpose would the broker want to keep this? It should not be needed for any complaint against the broker, so given that the lender should have seen these on application there would be no need for the broker to retain these.

Despite some of the unknowns at this stage, there are some areas which the industry should start to think about now. We hope that regulatory engagement will facilitate this.

Aileen Lees
Senior Policy Adviser


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