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…

AMI unveils The Perception Gap, the fourth annual Protection Viewpoint

This Viewpoint features hot topics facing the industry, including value of advice, building trust, consumer buying habits and generational views & attitudes…

Your October update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his October update, focusing on AMI’s Protection Viewpoint, new build and Consumer Duty…

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The Mortgages Market Study has a significant focus on technology and innovation.  In trying to put that into perspective it appears it starts with desire from government to change our market.  Earlier this year, the Department for Business, Energy & Industrial Strategy issued a green paper on “modernising consumer markets”.  It sought views on how to ensure that the markets are suitable for the modern economy and consumer.  The paper was based on principles that the government believes are key to responding to the challenges and opportunities of modern consumer markets:

The paper primarily focused on utilities but included references to financial services with government holding the following beliefs:

The Competition and Markets Authority (CMA) response to this paper included:

For each Parliament the government issues a non-binding Strategic Steer for the CMA.  The draft Steer sets out that the CMA should lead work with sector regulators to ensure the overall competition regime is co-ordinated and that consumers are protected from illegal and anti-competitive practices.  Government also wants the CMA to help consumers get the most from the digital economy, through building consumer trust in markets and enforcing the law to protect consumers and engage and lead the UK and international debate on competition and consumer policy in the digital economy.

In the FCA’s recently published annual report on competition it sets out how it provides “expert input on the financial services sector” to the CMA during its investigations.  In light of the government’s drive for “a world-leading digital economy” and the mandate it has given the CMA, it appears the approach taken by the FCA competition team has a deeper background.

In particular the Mortgages Market Study is all about enhancing choice and empowering consumers.  Industry concern is that this is ahead of the development of the technology, thinking and controls required in a lending based world with 25 or 30 year contracts.  This is very different to the annual or short term contract in the rest of financial services.  The importance of the protections afforded by advice needs to kept front of mind.

Robert Sinclair
Oct 18


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