Upcoming Webinar: what is a green mortgage?

The Green Mortgage Advice Initiative (GMAI) brings you a new webinar: What is a green mortgage. The event takes place on Monday 29th July…

Important fee changes for mortgage intermediary firms in 2024/25

The FCA has released its policy statement on the Fees & Levies payable by regulated firms for 2024/25 – we pull out the important fee changes…

AMI secures significant win for the protection industry

We are delighted that the FCA has accepted our argument that the protection industry should be out of scope of the Advice Guidance Boundary Review…

Mortgage Vision returns for 2024 with extra locations

This year’s Mortgage Vision events take place across the country in September and October, with some new locations added for 2024…

AMI Consumer Duty Factsheets update

Regulated firms are required to bring any closed products and services they continue to offer into the scope of Consumer Duty by 31 July 2024…

Your June ’24 update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his June update in what has been a quiet month for the industry with the upcoming general election…

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Press Releases

In a changing market such as financial services, AMI is the constant voice providing commentary on the issues that matter to members. We provide commentary and analysis through our press releases.

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19/11/2021 – AMI launches Protection: Moving forward, second annual report into protection market

The Association of Mortgage Intermediaries (AMI) today launches its second annual Viewpoint report on protection within the mortgage industry.

Protection: Moving forward, is based on extensive consumer and adviser research into the protection market and was produced in partnership with Legal & General and Royal London.

The report asked 5,000 consumers and 253 mortgage advisers a range of detailed questions about the protection market, some of which were the same as last year to see what has changed, while others were new to provide some additional and unique insight into the industry. Key findings from this year’s report include:

1 in 4 advisers are now passing protection business to a specialist, up from 1 in 7 last year
57% of advisers say protection discussions with clients have increased in the past 12 months and 42% say their clients are now more open to discussing protection
40% of 18-34s would consider Income Protection as a result of Covid-19 when they wouldn’t have before – that’s twice as many as those aged 35-54 (19%) and 10 times as likely as over 55s (4%)
99% of mortgage advisers say they raise protection with their clients, but two thirds of consumers don’t remember discussing it, up from just over half (53%) last year
55% of mortgage customers who used a broker have never bought protection products from them but cost is not the main reason – over a third (37%) don’t think they need it
42% of consumers think advisers only bring up protection to increase their commission but half (47%) would change their view if:
if their adviser took more time to talk about it (14%)
explained why they felt a protection discussion was important (20%)
or put more emphasis on how protection products could help them (19%)
52% of consumers think Income Protection (IP) is important yet only 7% have it

Commenting on the findings Robert Sinclair, Chief Executive, Association of Mortgage Intermediaries said:

“As with many reports there are both positives and negatives to draw on, with progress being made in some areas whilst others clearly show that we still have work to do. It’s positive that we are seeing consistent messages from consumers again this year, in the sense that we now have a clearer picture of areas that need our attention. Too many consumers distrust the motivations of their adviser. It’s important for us to have proper dialogue as a sector about how we overcome this – we hope it will be an area of priority for AMI’s Protection Specialists Group in 2022.

We would like to thank Legal & General and Royal London who have joined us again this year and made it possible to carry out this extensive research, as well as the many advisers who contributed to the report.

Craig Brown, Director, Intermediary Insurance at Legal & General said:

“There are some real positives to be taken from this – two in five advisers say their customers are more willing to have protection discussions as a result of Covid-19 and more than half have seen protection discussions increase in the past 12 months.

“However, the report also reveals that there is still a disconnect between the messages advisers think they are conveying about protection and what is actually being heard. There is already a great deal of support available from providers to help advisers with this challenge – at L&G we have a dedicated ‘Market Development’ team who are there to help brokers make sure their customers hear about the most appropriate cover at the right price – and we’ll continue to invest in services like this so we can support advisers to have better and more meaningful conversations with the goal of protecting more customers.”

Julie Scott, Chief Commercial Officer at Royal London Intermediary said:

“As society continues to recover from this crisis, we’re starting to see some interesting trends, especially in relation to how protection policies and protection advice are viewed. This report puts a spotlight on the current opportunities and challenges we face, as we work together to deliver the very best outcomes for our customers in a post pandemic world. One of the key issues is how to engage better with clients about the value of protection, and we all need to step up to the challenge of better equipping advisers so they can have more meaningful protection discussion and improve client awareness.”

AMI has produced Protection insurance – What should I know? a four-page consumer leaflet on the benefits of protection insurance to help brokers engage with their clients about the importance of protection, giving them the opportunity to either advise on that business themselves, or refer to a specialist, to ensure that a protection discussion is not lost.

12/11/2021 – AMI surprised by FSCS levy announcements

FSCS has today announced that it will not be invoking the Retail Pool in financial year 2021/22 or asking the FCA to invoice an interim levy on firms as part of this year’s costs.  The announcement today defers those costs into the next financial year as the losses that would have to be compensated have not yet materialised as firm failures have not yet crystallised.

In order to assist firms budget planning, FSCS has brought forward an estimate of its costs for the 2022/23 financial year.  This indicates that their total costs will be £900m, but this has a significant degree of sensitivity and will be updated again in the January consultation and then again in the April policy statement.  However, this could bring about a Retail Pool levy of circa £200m.  But, this is an “uncertain” number

Robert Sinclair, Chief Executive of AMI said:

“AMI is pleased to see that the FSCS does not need to invoke the Retail Pool for financial year 21/22, so avoiding an interim levy on mortgage and protection firms in the New Year.

For 22/23 we remain concerned about the costs being transferred from bad behaviour in the pensions and investment markets on our innocent member firms.  The continuing retail pool liabilities being added will not be charged until later in 2022, but this guillotine hanging over the heads of mortgage firms is stressful and unwelcome.

We are concerned that 73% of the FSCS costs come from advice more than 5 years ago.  This means that any actions taken by FCA today will have limited short term impact.  The industry needs a better solution to this compensation mess.

AMI stands ready to work with the FCA and FSCS to establish a better and fairer funding mechanism for the FSCS.  Previous work on the scheme has seen the FCA at its best in promoting constructive debate.  We hope the doors to a new debate will be opened soon.”

22/04/2021 – FCA concern over lack of Directory data from firms

AMI has been told by the FCA that over 2,800 firms are yet to submit their Directory Persons information.  From the communication that AMI has seen firms risk a fine if they do not provide the data in the next 7 days.  In addition, if not completed accurately they risk entering a pathway that could lead to having their regulatory permissions removed.  All firms including sole traders need to have completed this.

Robert Sinclair, Chief Executive of AMI said:

“There appears to be a significant number of investment and mortgage advice firms that have not advised the FCA of the requested adviser details by the end of March as required.

The FCA has written to all those firms giving them a short time to rectify the position.  AMI has written to all its member firms and are providing support to ensure they are all compliant.

Firms who are not members should take urgent action if they get an E-Mail from the FCA regarding the Directory and not ignore it as the implications are serious.”

20/04/2021 – Not the FCA fees transformation AMI wanted

It was to be hoped that the new team at the top of the FCA would be better than the group they replaced.  In their first major consultation on fees they have certainly transformed the approach.

A five week consultation on fees which is the shortest in memory
For the first time no published business plan to underpin the budget
The introduction of a new levy on networks which was not consulted on in the November policy proposals
Significant increases to the minimum fee on consumer credit where our members have no income, despite prior assurances
Significantly increasing their budgets by restating the categories of charge – increasing application fees with no commensurate reduction in on-going costs.

Robert Sinclair, Chief Executive of AMI said:

“It is disappointing that having acknowledged the huge spike in FSCS costs, the FCA is also intent on increasing the cost burden on firms at a time of falling revenues.  In apologising for having failed a number of consumers, it is again the good firms who remain who are picking up the bill.

I am particularly concerned that having found issues in controls over Appointed Representatives (ARs) in the Investments and General Insurance space, a broad brush approach has been applied without consultation.  To add a cost of £250 for each AR to a mortgage network without evidence of harm seems unfair.  AMI will be challenging this rushed change to the rules and the cost to firms robustly.

For what is another significant addition of new fee classes and costs, a five week response time leaves us very limited time to consult with our membership.

18/12/2020 – Mortgage sector cautions on impact of hard Stamp Duty deadline for homebuyers and sellers

The Intermediary Mortgage Lenders Association (IMLA) and The Association of Mortgage Intermediaries (AMI) are issuing this joint warning to members about buyers hoping to complete their property purchases before the Stamp Duty deadline of 31st March
Buyers need to be made aware that if they miss the deadline, they will be liable to pay the Stamp Duty – which in some cases could amount to thousands of pounds. Those who have not factored this additional cost in may have to withdraw from their purchase – causing chains to collapse
IMLA and AMI have suggested to Government a tapering of the Stamp Duty deadline in order to avoid transactions failing at the last minute

The leading trade bodies representing lenders and intermediaries in the mortgage market have cautioned that the upcoming March deadline to the Stamp Duty holiday is already causing significant congestion in the housing market. IMLA, which represents 43 UK mortgage lenders, and AMI, the trade body representing the views and interests of mortgage intermediaries, have both warned the home buying market is reaching a critical stage and that it is now likely that many cases will not complete before 31st March. The pressure is being caused by the significant surge in purchase transactions from July onwards.  Those buying properties for less than £500,000 will pay no Stamp Duty if they complete in time.  If they miss the date, however, they will be liable to pay the tax on the value of the property above £125,000 (the threshold for first-time buyers is £300,000).

The market has processed record levels of new applications from buyers whilst managing the varied and continuing impacts of COVID-19 on their businesses.  Once mortgage offers are issued and borrowers move on to try to achieve exchange and eventually completion, the pressure moves on to conveyancers, who are also facing record volumes of business.

IMLA and AMI have raised with Treasury our concerns that a large number of borrowers may not be able to meet the March deadline, through no fault of their own, in part caused by delays in obtaining searches, complex chains and the capacity impacts of firms operating in a Covid safe way. The result could be that borrowers are forced to borrow more funds to cover the costs of Stamp Duty, at a time when they may be stretched on their mortgage loan and additional borrowing may not be available.  We are concerned that the tax exemption cut-off with no taper could see a widespread collapse in property chains if buyers who planned to take advantage of the Stamp Duty holiday have not completed before 1st April 2021 and are forced to withdraw.

Kate Davies, Executive Director, IMLA comments:

“Unprecedented demand continues to put immense pressure on lenders, intermediaries and conveyancers, who are all working exceptionally hard to battle through the capacity challenges they face.  In addition to the myriad of operational challenges posed by the pandemic, the incentive to beat the stamp duty holiday deadline is increasing volumes of business.

“We are concerned, as we approach the Stamp Duty holiday deadline, that borrowers need to be realistic about what will happen if they miss the 31st March cut-off date.  Those who do miss it will need to be aware of how much Stamp Duty they may be liable to pay – and have a plan for finding that cash.  If they can’t – there is a risk that their sale may fall through – taking with it a number of other transactions if there is a chain.  Lenders, intermediaries and conveyancers will be as upfront as possible with borrowers and manage their expectations, but it is also vital that borrowers plan ahead and ensure they have the necessary funds in place.  We are asking all our members to work to increase post offer operational support, and our broker and conveyancer partners to assess their new business pipelines.  This will ensure as many complete before any deadline.”

We want to avoid borrowers losing out – through no fault of their own – and have called for some flexibility to the deadline which would ease the immediate pressure on lenders and conveyancers, and treat borrowers whose cases are already in the pipeline more fairly.  One way of doing this would be to taper the withdrawal of the tax exemption rather than apply a hard stop on 31st March. “

Robert Sinclair, Chief Executive, AMI comments:

“As the main contact point for the consumer at the sharp end of this, brokers will work hard to keep the consumer informed and warn them of the potential risks they face.  We are calling on lenders to ensure that their conveyancer partners have capacity to deal with the pipeline in front of them.  I would like all lenders, brokers and conveyancers to assess their pipelines and operational capacity between now and the end of March and give a realistic assessment to their customers of the likely outcomes.

By working together now we can minimise disappointment.  However, I firmly believe with what is already in the legal process, Government needs to stand ready to extend the deadline to avoid there being thousands of frustrated and disappointed taxpayers.

03/12/2020 – AMI announces election of new Chair

The Board of AMI has elected Andrew Montlake, Managing Director of Coreco Mortgages as its new Chair.  He takes over from Martin Reynolds, Chief Executive of Simplybiz Mortgages, who is stepping down after 3 years in the role, on 1 January 2021

Martin Reynolds said:

“I have thoroughly enjoyed my three years as Chair of AMI. It has been a privilege to be able to represent our fantastic industry. There have definitely been challenging times during this period, but Robert Sinclair and his team work tirelessly to ensure that the intermediary community is fully represented with the Regulator and other Trade Bodies. It is fantastic to have our first practitioner as Chair and I am sure that Andrew will use his influence and knowledge to continue to shine the positive light on the mortgage and protection advisers that we serve.”

Andrew Montlake said:

“It is a real honour to have been elected as AMI Chair and I would like to thank Martin for the outstanding job he has done over the past three years; these are big shoes to fill.

We have an amazing Board, who care passionately about the mortgage industry and we will continue to drive forward in a spirit of collaboration and partnership with lenders, Government and regulators.  It is important that AMI continues to lead from the front, helping to inspire future leaders of this industry, whilst being relevant and helpful to those within it. We need to ensure we openly encourage equality, diversity, and inclusion, to be more representative of society, our members and their clients.

Being a Chair who is a mortgage broker at heart, still advising clients, will help us show empathy with our members, be more reflective of both their and their clients concerns, and give credence to our discussions with regulators, especially in these challenging times.

I would urge anyone who has not engaged with AMI previously to do so; we are all stronger together and your voice is needed.”

04/11/2020 – AMI launches ‘The New Protection Challenge’ report

The Association of Mortgage Intermediaries (AMI) today launches a new report based on extensive consumer and adviser research.

‘The New Protection Challenge’ report, which asked 5,000 consumers and 500 mortgage brokers a range of detailed questions about the protection market in September this year was produced in partnership with Legal & General and Royal London. The 32 page report, which we believe is one of the most comprehensive studies of the mortgage protection market ever carried out, includes the following key findings:

97% of advisers say protection was mentioned in the mortgage process – but only 36% of customers remember it being mentioned, suggesting a perception gap between consumers and the industry
Buying a house or moving home are 2 of the 3 key drivers to buying protection, while home insurance is considered the most important insurance policy.

Less than a third of UK adults can correctly identify what income insurance is
Over half of consumers don’t believe protection claim statistics
The majority of consumers would prefer protection to be arranged before or during the mortgage process (not after)
1 in 7 mortgage brokers refer protection to a specialist
Covid-19 has not impacted the likelihood of getting protection for the majority of consumers

Robert Sinclair, Chief Executive of AMI said:

“The challenge our industry faces is how do we get the consumer onside and trusting this market during their journey through mortgage advice to protection advice. The research shows a great opportunity for advisers to better engage with customers. Our collective task is to encourage advisers to rise to the New Protection Challenge.

“We appreciate the partnership with Legal & General and Royal London to deliver this work of scale and would like to thank the many advisers who contributed to the report.”

Commenting on the research, Chair of the Protection Distributors Group, Alan Knowles said:

“The research is very enlightening and could suggest that if protection is being discussed with mortgage customers that it’s not always being done in a manner that impresses its true value and importance.”

Vikki Jefferies, Proposition Director at Primis added:

“With less than a third of UK adults able to correctly identify what income insurance is, it will be up to advisers to help boost consumer awareness on this product.”

David Ellis, Head of Strategic Partnerships at Royal London, commented:

“The big three findings are the lack of trust around claims statistics, the poor customer understanding around Income Protection, and the fact that the vast majority of consumers think life insurance is important but only the minority have it. We will continue to work with advisers and support them to overcome the challenges highlighted in the report.”

Craig Brown, Director, Intermediary Insurance at Legal & General, said:

“The report suggests a communication gap exists between what advisers think they are transmitting versus the messages customers are actually receiving. We would welcome an industry wide focus from insurers and distributors to highlight the importance of protecting all potentially vulnerable people and families.”

Launch of Protection Specialists Group

The launch of the report coincides with the launch of a new AMI Protection Specialists Group (PSG), which combines heads of protection, proposition directors and practitioners across a range of firms, networks and mortgage clubs.

The purpose of the group is to focus on pure protection and general insurance (GI) issues, providing insight and front-line experience into issues and opportunities facing the market.

Robert Sinclair, Chief Executive of AMI added:

“The PSG will help shape AMI’s policy and lobbying positions and develop future strategy in the protection arena. The AMI board wants to hear more from this group as there is a need for representation of member firms that distribute and provide advice on protection products, as this is a core aspect of work that member firms undertake.

“The group will discuss and debate topics that are currently relevant to GI and protection products and affect a mortgage intermediary firm. This will include: Market issues, Regulatory consultations, Industry collaboration.”

15/10/2020 – AMI Viewpoint – protection market research event launch

In September 2020, AMI, along with sponsors L&G and Royal London, commissioned market research company Opinium to obtain consumer and adviser views on the protection market. The research involved 5,000 UK adults and included a survey designed for mortgage and protection advisers.

The results of this research will be shared during a virtual launch event ‘The New Protection Challenge’ on the morning of Wednesday 4 November 2020 (9am for 9.15am start). The 30-minute event will discuss some of the key findings and include insight and analysis from industry experts.

The event will be accompanied by a report, which will include features from AMI’s Chief Executive Robert Sinclair, sponsors L&G and Royal London and Kevin Carr (Chief Executive of Protection Review and co-Chair of the IPTF), as well as the views of mortgage and protection advisers.

The event is open to AMI members, as well as non-members, via registration.

Registration for the event is open now, through this link.

Robert Sinclair, Chief Executive of AMI said:

“This event marks the re-launch of AMI’s ‘Viewpoint’ publication series. We decided to focus on protection as the inaugural topic, as we recognise that this is an important area of advice for mortgage intermediary firms.

This also supports AMI’s interest in the mortgage protection space. We recently launched our Protection Specialists Group, made up of individuals with mortgage and protection expertise from AMI member firms. The group aims to provide insight and front-line experience into issues and opportunities facing the market.

We recognise that there are many established groups who already focus on protection and carry out excellent work. Our aim is to not detract from this, but rather support and enhance it. Collaboration is important for our industry and we look forward to working alongside other protection groups, to meet the common goal of ensuring the correct consumer outcomes.”

28/09/2020 – AMI announces Board election timetable

AMI has announced details of its Board elections which will take place in November. As part of being an open and transparent body, which is fully representative of its members and their interests, the period for nominations for certain Board positions has now been opened.  These are part of the process where all Board positions are re-elected on at least a three-year rolling cycle, although existing members of the Board may stand for re-election.  This year’s Board elections will take place in the:

Mortgage Club constituency;
National firm constituency;
Network constituency; and the
Association of Finance Brokers constituency.

Any AMI member firm who falls under one of these constituencies can nominate a member of their senior management team to stand for election.  To stand, individuals must complete a nomination and also be nominated by an AMI member from within the same constituency.  Nominations must be returned to AMI by 26 October.

Should more than one AMI member per constituency want to stand for the Board, a contested election will take place.  Those individuals standing will be required to submit a biography and an election manifesto to those constituents eligible to vote.  Ballot papers for a contested election will be sent out by 3 November.

The results will be announced on 20 November.

Robert Sinclair, Chief Executive of AMI, commented:

“The AMI Board plays a vital role for the organisation in providing direction and policy guidance to AMI’s activities. Members wishing to serve as AMI Board members must be committed advocates of the intermediary distribution channel and prepared to represent not just their own constituents but the entire mortgage intermediary profession.  We hope AMI members will want to contribute to the trade body’s work and shape our ongoing agenda by standing for election.”

AMI members who wish to stand for election to the Board and are in any of the above constituencies can make the required nomination by e-mailing info@a-m-i.org.uk.  National firms are those with over 100 advisers.

03/07/2020 – AMI welcomes regulatory fees and levies savings for intermediary firms

The FCA yesterday published its policy statement and ‘made rules’ for regulated fees and levies 2020/21.

Whilst the FCA fees remain broadly level for mortgage intermediaries, firms whose turnover has remained consistent will see a reduction in total cost of regulated fees year on year, due, in the main, to a reduction in the levies paid for by mortgage intermediary firms towards the Financial Services Compensation Scheme.

AMI is delighted that our lobbying during the review of the FSCS in 2016-18 is showing real benefit to intermediary firms at an important time.

Robert Sinclair, Chief Executive of AMI said:

“AMI welcomes the reduction in FSCS fee costs for firms in the midst of this pandemic and at a time when capital resources are more challenging for firms.  We regret that firms with invoices over £10k will have to pay within 30 days, but are supportive that smaller firms will have 90 days to pay.

Whilst we are delighted that firms will not see a real increase in their total fees and levies costs this year, we remain acutely aware of the challenges faced by firms and the interrelation between capital adequacy requirements, PII, FOS and the FSCS costs. I was heartened to hear Charles Randell’s (FCA Chair) statement[1] that they needed to redesign the system to ensure that polluting firms in the financial sector pay, not those who have behaved well.  AMI will continue to work to hold the FCA to account and ensure that intermediary fees are proportionate to the risks posed.”

21/05/2020 – AMI calls for revision of FCA budgets for 2020

AMI has submitted its response to the FCA’s consultation on its proposed regulated fees and levies for 2020/21.

AMI is disappointed that the FCA did not echo the government’s approach of offering a raft of changes and support for firms of all sizes. Unlike HMRC’s approach to money laundering supervision fees, the FCA has prioritised its own agenda and plans for the next one to three years above the needs of the firms that it regulates.  The minutes of the FCA Board meeting of the 26 March detail that when considering a range of mitigations to ease the financial burden on firms the “balance between easing this burden and ensuring the FCA could deliver its business plan and meet its financial commitments was also considered.”  Consequently, the FCA prioritised funding for a business plan that was designed before the crisis hit and is now largely on hold and potentially out of date, over additional support for firms.

AMI calls for the FCA to focus on maintaining the integrity of the market for the recovery.  The mortgage intermediary sector needs support from the regulator to ensure that firms will survive this crisis both in the short-term, but also into next year when cash-flow levels may not have fully recovered.

Robert Sinclair, Chief Executive of AMI said:

“Whilst we support the freezing of fees for smaller firms, we cannot support this cost transfer to larger firms.  The changes to the proposed fees in light of the Covid-19 pandemic should have been greater and further reaching.  We are concerned that the FCA’s fee proposals neither reduce its current expenditure nor suggest an intention to reduce spending next year in view of the likely reduced turnover of and indeed likely reduced number of regulated advisory firms.  The FCA should look to reduce operational costs where possible rather than continuing along the path that was deemed appropriate pre-crisis.  Essential costs including authorisation, supervision and enforcement must be prioritised over strategy and competition agendas until there is a clearer view of the post-lockdown landscape.

Mortgage intermediaries will be vital in the new world where consumers are more vulnerable and with higher amounts of both secured and unsecured debt.  People will need good quality advice to help them to understand the best product available, under their potentially changed circumstances, to meet their needs.  As with the trapped borrower cohort, advice will be key.  This budget should be referred back to the Board to reconsider its position.”

19/05/2020 – AMI welcomes insurer changes following FCA guidance

On 14 May 2020 the FCA confirmed guidance for insurance and premium finance firms, with the aim to help customers who may be facing financial difficulties due to coronavirus. It applies to GI and protection contracts and aligns the assistance available to options provided for other financial products, such as mortgages and unsecured loans.

AMI is supportive of insurers who allow customers to pay back deferred payments over a period of months, as the ability to stagger repayments rather than in one lump sum may encourage the customer to keep their cover in force, instead of cancelling a direct debit. This ensures that cover such as protection continues uninterrupted.

Insurers need to be clear on how they deal with broker commission during a customer payment deferral and a sensible and fair approach would be for there to be no impact on commission. Some insurers have already confirmed this, and AMI encourages transparency from other insurers.

Within their statements on payment deferrals many insurers have recommended financial advice. It is crucial that customers understand the effects of deferring payments and receive advice to assess whether this is the best option given their circumstances. Mortgage intermediaries are well placed to provide advice and is why it is so important that insurers communicate clearly and promptly to intermediaries what customer assistance is available.

Stacy Reeve, Senior Policy Adviser at AMI said:

“Protection and general insurance advice during these times is more important than ever and intermediaries, many of whom have built strong relationships with their customers and are a trusted adviser, can help customers to understand the options available.

Communication between insurer and intermediary is also key so that the help can reach those customers who need it the most. The FCA has been clear that they will want to see firms across the distribution chain working together to ensure that customers are treated fairly, so joined-up communication is vital.

Intermediaries may wish to use this FCA guidance to ignite protection discussions with their customers. Customers may be actually or potentially vulnerable and the uncertain situation we find ourselves in can be very unnerving for many. Ensuring that customers maintain appropriate cover has got to be the aim”.

14/05/2020 – Getting the UK moving

Following lobbying work and policy development by a range of trade bodies including AMI and member firms, the government has issued updated guidance on home moving during the Covid-19 outbreak to make clear that people who wish to move home can do so.  The guidance provides important public health based information for both the public and the industry to ensure that moving home and key activities around this, such as viewing property, can happen safely.  AMI welcomes and is supportive of these changes which put our industry right at the heart of restoring economic activity in the country.

AMI expects that the full return to operations may take some time.  As government guidance is clear, staff should continue to work from home if at all possible.  The vast majority of mortgage advice can be completed from home via IT support and telephone.  Employers have a legal responsibility to protect workers and others from risk to their health and safety.  This means they need to think about the risks their employees face in estate agency, new build and other office environments and do everything reasonably practicable to minimise them.  Many businesses have furloughed staff and will need to decide who to bring back and when.  Staff will need additional training to ensure that they understand the new requirements and procedures which will take longer and be more complex.  The majority of activity will need to be by appointment and be with people from single households.  All businesses should continue to follow the government’s latest guidance for employers and businesses on coronavirus and safer working guidance.

Robert Sinclair, Chief Executive of AMI said:

“This does not represent a return to normality.  The process of finding and moving into a new home will need to be different given those involved in the process will have to adapt practices and procedures to ensure that the risk of the spread of coronavirus is reduced as far as possible.  However, it does signal that firms involved in new build sales and advice, estate agency, valuations, conveyancing and removal as well as mortgage advice can open and transact.

Adherence to social distancing and the highest safety standards will be absolutely paramount and all precautions will be taken to protect people viewing property.  We also have new industry guidance covering estate agents, valuations and moving which has been developed to ensure we keep people as safe as possible in the process.  Getting physical valuations and removals back makes a big difference, but we all have a role to play in ensuring everyone acts responsibly.”

28/04/2020 – AMI responds to UK Finance payment holiday press release

Following the UK Finance announcement of the industry agreement allowing PTs to be taken by consumers who have had a payment holiday agreed or have been furloughed, AMI responds to say that consumers should take mortgage advice so that they understand the options available to them.

AMI supports lender flexibility on product transfers in the current climate, however consumers should not be led to think that this is the only solution. AMI is concerned that this approach steers consumers down one path and raises the question whether this approach is in the customers’ best interests.

When mortgage payment holidays were announced, it was commented by many that they should not be viewed as the only solution and this same logic needs to apply once a consumer reaches the end of their mortgage incentive period.

UK Finance in a blog released today on this topic comments that “for those who want help selecting the right product for them, advice is widely available from both mortgage brokers and lenders”. This is a view which AMI fully endorses.

Robert Sinclair, Chief Executive of AMI said:

“Whilst this support for consumers is positive and avoids the consumer falling onto a lender’s SVR, it is inward-looking as it makes no consideration as to whether the deals offered are appropriate.

Some customers may find that if they revoke their mortgage payment holiday and re-mortgage, it could result in a more suitable outcome. They also may not be aware of how a specific deal compares to others in the marketplace.

As a result of Covid-19 many more consumers may be vulnerable, so it is vitally important that they explore their options. Whilst a PT may seem the most straightforward option, consumers should talk to a mortgage broker as they are well placed to assess individual circumstances”.

21/04/2020 – Guide to saving protection policies

Covid-19 is resulting in financial difficulty for many and may lead to clients cancelling their protection insurance direct debits. Whilst the current crisis is not directly comparable to the financial crisis of 2007/08, many advisers who were working in the industry at that time will recall the same happening and recognise the need to be proactive.

Advisers are well placed to engage and educate their clients about the benefits of their existing policies, as well as discussing alternative options to cancellation. It is important that clients make an informed decision and not one that is in haste, without due consideration given to how injury and illnesses are still a threat to everyday life.

To assist advisers, the Association of Mortgage Intermediaries (AMI), the Protection Distributors Group (PDG) and the Income Protection Taskforce (IPTF) have, in collaboration, created a guide to suggest ways that advisers can offer support and guidance to their clients to ensure that cover is maintained.

The guide, which is being made widely available, can be found attached to this press release.

Robert Sinclair, Chief Executive of AMI said:

“Before Covid-19 hit, income protection policies sales were increasing and the ‘Access to Insurance’ sign posting agreement made positive strides to help clients with disabilities and medical conditions find suitable cover.

It is important that this momentum is not lost, as protection needs continue to exist. The value that intermediaries add is crucial to ensuring clients realise the far-reaching effects that cancelling cover could have on their lives.

Many intermediaries are already contacting clients and generating discussion, but AMI, PDG and IPTF hope that this guide will be a useful tool. It was important for AMI to collaborate with the PDG and IPTF during these difficult times and to make sure as many people as possible benefit from the content.”

01/04/2020 – FCA and other regulatory fees for 2020

AMI has been in discussion with the FCA over the 2020/21 regulatory fees to be levied on member firms.  Given the extreme situations facing society and firms we have requested that FCA considers deferring or reducing the fee costs facing firms.

The FCA has indicated that it will consult as part of its normal fees process on assisting smaller firms for July invoicing.  There is no detail as yet on what that might comprise, but we warmly welcome the support being considered.  However, the 1100 larger firms under FCA authorisation are required to make their “On Account” payments today, 1 April.  These represent the bulk of the fees due in the year.

AMI considers that discriminating in favour of smaller firms is unfair on our other members.  These larger firms have the same overheads and costs in proportion as smaller firms.  Whilst able to meet these costs, these larger firms need to preserve cash to protect their business and staff in the same way as all in the economy.  In making decisions which might include pay reductions, furlough or redundancy, having to make these payments increases the likelihood of having to make decisions which impact on people and their longer term business.

The housing and mortgage markets are changing rapidly and significantly.  The FCA needs to be focussed on maintaining the integrity of the market for the recovery.  We do not see the FCA making similar sacrifices as this week it announced the launch of its 2020 Apprenticeship Scheme.  It continues to operate “business as usual” as the firms it regulates struggle to manage their customers’ expectations whilst working from home.

Robert Sinclair, Chief Executive of AMI said:

“We have asked for support for all our firms and have received some comfort.  Firms are making decisions today to ensure they are here to support the recovery as we come out of lockdown.  All firms need the same backing and I call on the FCA to reconsider this decision and not penalise larger firms by taking important cash from their bank at this difficult time.  These firms are planning cash flow to year end and would really benefit from retaining cash in the business.  We believe that Government should be supporting the costs of our regulators at this time.”

26/11/2019 – AMI Board elections

AMI has now completed its election process and the results are:-

The Practitioner Constituency (3 vacancies) – Andrew Montlake (Coreco) and Scott Taylor-Barr (Carl Summers Financial Services) are re-elected and Abi Greenhalgh (Nest Financial Services) is elected.
The Regional Constituency (2 vacancies) – Ray Boulger (John Charcol) is re-elected and Dan Maskell (The Finance Planning Group) is elected.
The National Constituency (1 vacancy) – Will Hale (Key) is re-elected.
Network Constituency (2 vacancies) – Richard Howells (Sesame) is elected and Peter Curran (Countrywide/Mortgage Next/Mortgage Intelligence) is re-elected.

Robert Sinclair, Chief Executive of AMI said:

“This process ensures that the membership affirms that it is being properly represented.  I would like to thank all those who stood for election which ensures a democratic process.  I would also like to express my sincere thanks to John Whyte of The Right Equity Release for his contribution during his six of service and support.”

7/10/2019 – AMI announces Board election timetable

AMI has announced details of its Board elections which will take place in November. As part of being an open and transparent body, which is fully representative of its members and their interests, the period for nominations for certain Board positions has now been opened.  These are part of the process where all Board positions are re-elected on at least a three-year rolling cycle, although existing members of the Board may stand for re-election.  This year’s Board elections will take place in the:

Regional firm constituency;
National firm constituency;
Network constituency; and the
Practitioner constituency.

Any AMI member firm who falls under one of these constituencies can nominate a member of their senior management team to stand for election.  To stand, individuals must complete a nomination form and be nominated by an AMI member from within the same constituency.  Nomination forms must be returned to AMI by 28 October.

Should more than one AMI member per constituency want to stand for the Board, a contested election will take place.  Those individuals standing will be required to submit a biography and an election manifesto to those constituents eligible to vote.  Ballot papers for a contested election will be sent out by 8 November.

The results will be announced on 29 November.

Robert Sinclair, Chief Executive of AMI, commented:

“The AMI Board plays a vital role for the organisation in providing direction and policy guidance to AMI’s activities. Members wishing to serve as AMI Board members must be committed advocates of the intermediary distribution channel and prepared to represent not just their own constituents but the entire mortgage intermediary profession.  We hope AMI members will want to contribute to the trade body’s work and shape our ongoing agenda by standing for election.”

AMI members who wish to stand for election to the Board and are in any of the above constituencies can request a nomination form by e-mailing info@a-m-i.org.uk.  Regional firms are classed as having between 6 and 100 advisers; national firms with over 100 advisers and practitioners must be members who spend at least 70% of their working week advising customers on mortgages and related needs.

13/05/2019 – AMI challenges content of Government How to Buy & How to Sell homes guides

On 7 May 2019 the Ministry of Housing, Communities and Local Government published these new guides.  AMI has been is discussion with MHCLG during the creation of these and since publication.  We have asked for alterations to the documents some of which have been refused.

We are advising our member firms of the content of these documents as they may be unaware of the potential impact.  Within the text there a number of embedded links to a membership-based consumer charity.  When taken to the linked pages users will then be offered the option to talk to one of the mortgage advisers in their connected commercial arm.

We have asked for sight of any due diligence, tendering processes or internal approval processes, but have not had this shared.

We will continue to raise our concerns over this implicit endorsement of one advisory firm over others and lobby to have this changed.

Robert Sinclair, AMI Chief Executive said:-

“We are extremely disappointed at the approach taken here on what are an otherwise excellent series of documents.  However, we cannot support or endorse the promotion of one advisory firm, even indirectly at the expense of others.  AMI has always championed a level playing field on all matters and will continue to do so.

We hope that MHCLG will reconsider their approach and move to a more balanced position.”

https://www.gov.uk/government/publications/how-to-buy-a-home

https://www.gov.uk/government/publications/how-to-sell-a-home

31/01/2019 – FSCS published its 2019/20 plan and budget

The Financial Services Compensation Scheme has today confirmed its plan and budget for 2019/20. Mortgage brokers will see a significant fall in the amounts invoiced by the FCA this year, as they will no longer be paying towards pensions and investment claims which are estimated at £175m this year.  All intermediary classes will also gain from the provider contributions now coming into force.

This year’s levy for mortgage claims is estimated at £5m, but only £4m will be levied on brokers as the remaining £1m is paid by lenders.  It is positive to see the claims level fall from £25m paid by mortgage brokers last year.

Robert Sinclair, Chief Executive of AMI said:

“This has been a two year journey to achieve a fairer outcome for all mortgage brokers and it will have a significant impact on this year’s fees.  This was a significant win for AMI who were often the only entity arguing for these new and fairer class allocations and for the new 25% provider contributions.”

21/01/2019 – AMI annual dinner 2019

TSB has agreed to sponsor the Association of Mortgage Intermediaries (AMI) dinner to be held on 20th June this year at the Sheraton Park Lane in London.

The annual summer networking dinner with top ranking entertainment continues to attract over 300 attendees from the mortgage lender and advice sectors.

Roland McCormack, TSB’s mortgage intermediary director, said:

“We are delighted and honoured to be sponsoring the AMI dinner. The work Robert and team do on behalf of brokers is vital in ensuring we have a strong and vibrant Intermediary sector, focused on giving quality advice and product choice to customers.”

Robert Sinclair, chief executive of AMI said:

“I am really pleased that TSB has become the second ever sponsor of the AMI Annual Dinner.  As a significant challenger Bank who are keen to be at the front of innovation and change in the market and as passionate advocates of the intermediary, it is great to have them supporting our main event in the mortgage calendar.  The AMI Board is delighted to welcome the partnership with Roland and the team.”

11/12/2018 – AMI annual dinner 2019

After 15 years, AMI and Santander have agreed that it is the right time to find a new sponsor for the AMI Annual Dinner.

Robert Sinclair, AMI Chief Executive said:

“I and the AMI board are exceptionally grateful for the generous support the team at Santander have provided over the last fifteen years.  This has been a significant commitment by a lender which has always shown tangible investment in the intermediary sector.  We are now moving into a new era, but will always recognise what this sponsorship delivered, particularly as we became established as an independent trade body. A big thank you to Miguel, Brad and the team.”

Brad Fordham, Managing Director of Santander for Intermediaries said:

“This was not an easy decision, but the right one for both organisations now.  We will continue to support and work with Robert and AMI on industry and policy issues as we always have.  This gives other lenders the opportunity to support one of the key dinners in our industry.”

25/10/2018 – AMI objects to increasing the FOS claims limit

Last week the FCA proposed increasing the compensation limit of the Financial Ombudsman Scheme (FOS) from £150,000 to £350,000.  AMI strongly opposes this significant increase.

By more than doubling the compensation limit the FCA has lost sight of both its own and FOS’s purpose.  FOS was set up with a £100,000 limit and raised to £150,000 in 2012 in line with inflation.  Its purpose was to cater for cases that could be dealt with speedily and by using dispute resolution techniques to gain agreement.  Cases above these levels were deemed to be more appropriate for legal decisioning in courts based on contract law.

Robert Sinclair, Chief Executive of AMI said:

“Accessing dispute resolution for such significant cases on a fair and reasonable basis rather than a proper legal dispute procedure through the courts is just inappropriate.

Just because there are examples of higher claims being paid out does not warrant a radical increase to the FOS limit.  Even most of the respondents who agreed to the extension of FOS eligibility to include larger SMEs did not support an increase to the limit, with only three suggesting that it should be that high.  Relying purely on data analysis is not a sufficient justification.  It was always considered that higher value disputes with complex arguments should be the subject of legal remedy rather than FOS.

AMI will respond to the consultation accordingly and we encourage individual firms to do the same.”

19/10/2018 – AMI concerns over FCA extension to the Financial Ombudsman Scheme

AMI is deeply concerned around the FCA’s approach to the changes to the Financial Ombudsman Scheme (FOS).  This week the FCA confirmed it will extend access to FOS to include larger SMEs.

The FCA announced that respondents had “strongly supported” this extension of FOS. There were 65 responses, 13 of which raised fundamental objections to extend the eligibility.  There has been a failure to recognise that most of these were raised by trade associations who respond on behalf of their members and represent their respective sectors.  We consider that the voices of and the fees paid by mortgage and protection advisers; investment and financial advisers; asset, consumer and motor finance providers; general insurance brokers; life assurance and wealth management firms; wholesale insurers and reinsurers; electronic money issuers; and debt collection companies are not insignificant.  We also believe that the claim to have received agreement from the “significant majority” is misleading, particularly as a fifth of those who agreed were from individuals or SMEs themselves.

Robert Sinclair, Chief Executive of AMI said:

“By diminishing the pushback to this extension it is apparent that the FCA had already decided it was going ahead with its proposals and has tried to find the justification.  To take the number of responses into account rather than who they represent is a skewed approach to analysing feedback.

The minutes from the FCA’s Board meeting in July, published nearly a week before the policy statement, show that this was not even a consideration in their decision.  It has never been intended that those acting for business or professional reasons are afforded the same protections as consumers.  However we are moving to a world where the regulator considers every area of ‘harm’ as their responsibility and that it is easier to simply widen its scope rather than address the issue directly.   Accessing dispute resolution on a fair and reasonable basis rather than a proper legal dispute procedure through the courts is just inappropriate.”

12/10/2018 – AMI response to the creation of a Global Financial Innovation Network

AMI has responded to the FCA consultation on creating a new Global Financial Innovation Network comprising international regulators. The proposals set out the functions of the forum and the introduction of a global sandbox.

It however omits fundamental information, particularly the costs of the GFIN and how they will be apportioned to firms.  The FCA is legally required to undertake and publish a cost benefit analysis (CBA) before proposing or amending rules with CBAs having been historically included as part of any consultation, on the basis that the regulator has considered them to be “about transparency” and “an important part of the FCA’s accountability framework”.  For such significant proposals to lack any estimate of costs and whether they are proportionate to the potential benefits contradicts its commitment to transparency and the overall requirement to be transparent.

In publishing this paper the FCA referred to these proposals as following an initial consultation in February 2018 to which 50 responses were received.  However we have been unable to locate this “initial consultation” on the FCA website nor does it appear to have been made public to fee-paying firms.  It is AMI’s view that this has been developed on the basis of limited discussions with ‘innovative’ firms.  The FCA’s 2018/19 Business Plan, published in April, stated that “last month we invited stakeholders to share their views on what a global sandbox could look like; there is a lot of interest in the idea of cross-border testing and the benefits this could bring”.  This is the only prior public reference to its work on a global sandbox.  AMI has asked the regulator to publish its “initial consultation”, a list of the 50 ‘respondents’, and the stakeholders involved in these working groups (including the proportion of authorised and non-authorised firms and the percentage that these firms contribute to the FCA’s fees).

Robert Sinclair, Chief Executive of AMI said:

“We are concerned that the FCA continues to expand its innovation agenda by expanding its remit and objectives, and inappropriately allocating resources with a disregard for the firms that fund it.

The FCA is expected to focus on relevant consumer and market issues, so helping overseas technology firms become authorised in the UK should not be a priority.  It is already being anti-competitive with its existing sandbox as it gives dedicated regulatory support for some unauthorised firms (paid for by industry) whereas regulated firms have only the FCA call centre as a point of contact.  To extend this cross-subsidisation of costs on an international scale is inappropriate for a domestic-facing regulator.  The global sandbox will only benefit the firms that are in it and the FCA’s reputation for facilitating innovation.

We are seeing a regulator that is less transparent and less willing to listen to feedback.  This is a consultation in name only and we think that these proposals have been developed with selected stakeholders, with discussions mislabelled as consultations, and will no doubt continue to be implemented without any consideration of costs or industry feedback.”

Our response can be found here.

09/10/2018 – AMI response to the new FCA directory

AMI has responded to the FCA consultation on a new directory which will continue to show Appointed Representatives after the Senior Managers & Certification Regime has been extended.  This meets the requirements set out under the Mortgage Credit Directive.  AMI supports the addition of mortgage advisers to this list to enhance transparency for firms and consumers.

AMI has identified a lack of co-ordination between related consultations and the duplication of remit.  The Work and Pensions Select Committee asked the FCA to improve its register, specifically to ensure that consumers could check if a firm or individual has had their permissions restricted or suspended.  The FCA is however proposing to go further than these recommendations by creating a tool for consumers to find advisers even though this facility is already provided by the Money Advice Service (MAS).

Robert Sinclair, Chief Executive of AMI said:

“We are concerned that the FCA appears to be working in siloes both internally and distinct from organisations it’s supposed to be collaborating with.  There is a risk of a waste of resources.

AMI perceives that there is a regulatory view that MAS is a third party on par with a commercial firm, whereas MAS is a statutory body funded by industry in the same way as the FCA.  The memorandum of understanding between MAS and the FCA commits to “minimise inconsistency and duplication and to promote coordination” by “working together on information aimed at consumers”. We would have expected the FCA to consider MAS’s existing retirement adviser directory rather than the duplication set out in these proposals.  The FCA should have also consulted more widely before adding this function to the current register.

These proposals directly cut across the Mortgages Market Study work on broker choice published in May 2018, and we are asking the competition team to reconsider their plans given this directory consultation published in July.  The new directory will show a list of all advisers, including mortgage advisers, and the information that will be displayed addresses most of the issues raised in the market study.  Firms shouldn’t be asked to pay for two pieces of similar work running side by side. Our view is that the new directory should stop at the point of outlining firms’ permissions and any search facility to find an appropriate adviser should sit within the adviser directory held by MAS and its successor.”

08/10/2018 – AMI announces Board election timetable

AMI has announced details of its Board elections which will take place in November. As part of being an open and transparent body, which is fully representative of its members and their interests, the period for nominations for certain Board positions has now been opened.  These are part of the process where all Board positions are re-elected on at least a three-year rolling cycle, although existing members of the Board may stand for re-election.  This year’s Board elections will take place in the National firm constituency, the Network constituency and the Club constituency.

Any AMI member firm who falls under one of these constituencies can nominate a member of their senior management team to stand for election.  To stand individuals must complete a nomination form and be nominated by an AMI member from within the same constituency.  Nomination forms must be returned to AMI by 29 October.

Should more than one AMI member want to stand for the Board, a contested election will take place.  Those individuals standing will be required to submit a biography and an election manifesto to those constituents eligible to vote.  Ballot papers for a contested election will be sent out by 12 November.

The results will be announced on 30 November.

Robert Sinclair, Chief Executive of AMI, commented:

“The AMI Board plays a vital role for the organisation in providing direction and policy guidance to AMI’s activities. Members wishing to serve as AMI Board members must be committed advocates of the intermediary distribution channel and prepared to represent not just their own constituents but the entire mortgage intermediary profession.  We hope AMI members will want to contribute to the trade body’s work and shape our ongoing agenda by standing for election.”

AMI members who wish to stand for election to the Board and are in any of the above constituencies can request a nomination form by e-mailing info@a-m-i.org.uk.  National firms are classed as having over 100 advisers.

31/07/2018 – AMI response to the FCA Mortgages Market Study

AMI has submitted its response to the interim report which set out the FCA findings and the way they would like to see the market develop.  AMI has been involved in numerous meetings, discussions and debate with the market study team, our fellow trade bodies and a wide range of market participants.

Robert Sinclair, Chief Executive of AMI said:

“Our main concern with this report has been the focus on price without any validation of the quality of the advice or whether the “cheaper lenders” have the capacity to handle the business assessed.  AMI were strong supporters of the move under MMR to a wider definition of suitability and remain concerned that this report ignores these fundamental market improvements.

We are keen to support a tool that allows consumers to access a database of brokers and see what services are provided in a useful way.  The Money Advice Service Retirement Adviser Directory already provides this for pensions advice and it was originally intended to extend this directory to include mortgage advisers.  In addition, the FCA is consulting on its own Directory of Advisers.  We will liaise with the FCA and the Money Advice Service to consider if these or other approaches would provide the most effective solution. We are however struggling to identify “quality measures” which would fairly differentiate between advisers.

On the work to improve eligibility criteria we are firmly of the view that initiatives in the last 12 to 18 months have moved this agenda forward significantly.  Intervention now may limit or slow innovation, therefore we are keen to avoid making changes of the type suggested.

We are aware that our fellow lender trade bodies are working with their members on improving the situation of mortgage prisoners and hope that the plans deliver an overall improved position.

We will continue to work with the FCA over the coming months to ensure that any proposals meet the needs of consumers and work effectively for all market participants.”

24/05/2018 – AMI researches the “Free Legals” market

AMI recently surveyed its membership to ascertain how intermediaries are using the “free legals” services offered by many lenders.

In response to a series of questions brokers told us that 73% only recommend free legals on remortgage; 19% on both purchase and remortgage; and 8% do not recommend free legal based products.

82% of brokers told us that the service delivered by “free legal firms” is worse or significantly worse (52%) in comparison to a customer’s own choice of solicitor/conveyancer.

57% preferred a cash-back option (26% preferred products with free legals).

71% of those responding indicated that they were experiencing delays and issues with those providing free legal services.

75% of intermediaries thought that lenders or builders should not offer “free legals” as this is too great a conflict of interest.

Respondents commented “the standard of service is generally poor”.  “Lenders are aware the service is abysmal but they still continue using these firms and that is reprehensible”.  “Not able to get through by phone, missing completion dates – terrible”.  “Firms don’t have one legal adviser dealing with a case, it’s whoever picks up the phone…post is regularly lost… I have to warn the client the process will be bumpy”.  “I prefer cashback products then I can choose which remo solicitor we use.”  “Certainly on a purchase a client should choose their own legal representation.”

Robert Sinclair, Chief Executive of AMI said:

“This survey raises a number of questions on the effectiveness of the free legal services offered to many consumers.  It is clear that the significant majority of brokers would prefer a cashback option where lenders feel that they wish to incentivise aspects of their products.

AMI thinks that all lenders should reconsider their offering of free legals particularly addressing the potential issues of conflict of interest and the quality of service being provided by the firms with whom they have partnered.

AMI will be talking to their lender trade body contacts about these findings.”

04/05/2018 – FCA publishes mortgage market study interim report

AMI welcomes the FCA’s view that the mortgage market is generally working well, that most consumers are switching and that the value of intermediaries is recognised.  We are also pleased that the FCA found little evidence of commercial arrangements causing material harm for consumers and no existence of commission bias, which is consistent with its previous findings four years ago.

Robert Sinclair, Chief Executive of AMI said:

“We are pleased to see agreement that the issue of mortgage prisoners, whilst smaller than anticipated, is now acknowledged as significant.  This needs to be tackled and we would like to see lenders taking a more pro-active approach.  In addition, the report provides evidence of the scale of product transfers business which remains unreported.  As it now clearly comprises more than a third of the market, we think that UKFinance and the FCA need to gather and publish this data to reflect its significance.

We are happy to work with lenders to help them meet the existing rules on lenders openly publishing criteria to assist in the Decision in Principle process.  We are however concerned about the view that the advice and suitability rules are hindering consumer choice.  Any dilution of the rules to facilitate online solutions will need careful assessment as the Mortgage Market Review rightly recognised the need to establish, through advice, the suitability of a mortgage for a customer.  The FCA has always stressed that suitability is not price-driven so this is a significant attitude shift.  Anything which will dilute the opportunity for consumers to benefit from advice runs the risk of moving the industry and consumer protections significantly backwards.

We are keen to support a tool that allows consumers to compare the service provided by brokers.  The Money Advice Service already provides this for pensions advice and it was originally intended to extend this directory to include mortgage advisers.  We will work with the FCA and the Money Advice Service to consider if this or other approaches would provide the most effective solution.”

01/05/2018 – FSCS funding review

AMI is delighted that the FCA has listened and agreed with our arguments for a fairer arrangement for mortgage brokers.  From April 2019 mortgage brokers will no longer have to pay for the mis-selling of personal pensions and investment business.  Instead pure protection will form part of the general insurance distribution class.  In addition, all intermediary classes will now benefit from a 25% contribution to costs.

This has been a two year journey to achieve a fairer outcome for all mortgage brokers and it will have a significant impact on the fees levied from 2019.

Robert Sinclair, Chief Executive of AMI said:

“The senior management of the FCA listened to our logical arguments and agreed that these changes were sensible.  We believe that these amendments to the funding of the FSCS should deliver a more balanced industry in the future.  In resisting strong lobbying from the provider community, the FCA has stood up in support of smaller advice firms.”

30/01/2018 – AMI Chairman steps down

It is with great regret that AMI has accepted the resignation of its Chairman Pat Bunton as he has stepped down from his role at London & Country mortgages.

This will put in train a process for the Board to elect a new Chairman from within in accordance with the membership rules.  London & Country will nominate a replacement to the Board in due course.

The day-to-day work of AMI will continue through its employed executive team.

Robert Sinclair, Chief Executive of AMI, commented:

“I have had the distinct pleasure of working alongside Pat as AMI Chairman for just over five years, in addition to the period before that when he was a fundamental part of the team that extricated AMI from AIFA.

Pat has been a passionate advocate of consumer-focused advice and the role that advisers play in delivering great results to the UK population.  He has given his time and considerable expertise and knowledge for no reward other than knowing he was doing the right thing.  The intermediary sector owes him a great debt for the work he has done on MMR, mortgage prisoners, the ongoing competition review, revision to the Compensation Scheme and a regulator that listens to the mortgage advice community.

In addition he has delivered a financially robust independent trade body which is respected at the highest levels within the regulatory community.  His input will be missed by the team, the Board, the FCA, Bank of England and Treasury.  These will be big shoes to fill.

I would also like to thank the team at L&C who gave us Pat and his contribution without ever counting the many hours we took up.”

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30/10/2017 – FCA consultation on reviewing the funding of FSCS

The FCA has today issued a further consultation on reviewing the funding of the Financial Services Compensation Scheme (FSCS).  This follows on from its consultation paper issued December 2016 and a series of roundtable discussions and meetings which AMI has been involved in over the last year.

Over the last two years AMI has argued for much needed reform, which we set out in our response in March, with the right solution involving a restructure of the FSCS classes to ensure greater affinity across the product classes.  With the majority of claims in the life and pensions intermediation class relating to mis-sold SIPPs, it is grossly unfair that mortgage firms as the primary writers of life insurance have been paying a disproportionate amount of investment advisers’ invoices despite no connection between the two business lines.  We are pleased to see that the proposals have been revised so that the FCA is now consulting on moving pure protection intermediation from the Life and Pensions funding class to the General Insurance Distribution class.

AMI has also strongly supported the inclusion of provider contributions to the intermediary classes, which we believe mistakenly disappeared from the FSCS structure at the time the FSA split in 2013. Its reintroduction will only accurately reflect the existing regulatory landscape and will hopefully focus all minds more clearly on their respective responsibilities and accountability.

AMI will be responding to the consultation before its closes on 30 January.

Robert Sinclair, Chief Executive of AMI said

“We have been tirelessly lobbying several issues with the FSCS structure and we are pleased that the significant work we have carried out with the FCA over the last year is materialising.  To see revised proposals include the removal of protection from the pensions class is positive as this will greatly impact mortgage intermediaries’ bills.  The fact that the FCA has decided to re-consult with industry rather than proceeding with one of the proposals set out in the last paper is encouraging.  They have not only listened to our concerns but are openly engaging with industry to ensure that they implement the fairest solution.

We are pleased that the FCA has recognised that providers are also responsible for the distribution of their products.  Whilst the proposed provider contribution of 25% is not as high as we had hoped for, it’s a step in the right direction.

We are really happy that the work done since the first consultation has paid off with a further consultation which reflects our long-term lobbying position.”

11/10/2017 – AMI announces Board election timetable

AMI has announced details of its Board elections which will take place in November. As part of being an open and transparent body, which is fully representative of its members and their interests, the period for nominations for certain Board positions has now been opened. These are part of the process where all Board positions are re-elected on at least a three-year rolling cycle, although existing members of the Board may stand for re-election. This year’s Board elections will take place in the Regional and National firm constituencies, the Network constituency and the Club constituency.

Any AMI member firm who falls under one of these constituencies can nominate a member of their senior management team to stand for election. To stand individuals must complete a nomination form and be nominated by an AMI member from within the same constituency. Nomination forms must be returned to AMI by 1 November.

Should more than one AMI member want to stand for the Board, a contested election will take place. Those individuals standing will be required to submit a biography and an election manifesto to those constituents eligible to vote. Ballot papers for a contested election will be sent out by 13 November.

The results will be announced on 30 November.

Robert Sinclair, Chief Executive of AMI, commented:

“The AMI Board plays a vital role for the organisation in providing direction and policy guidance to AMI’s activities. Members wishing to serve as AMI Board members must be committed advocates of the intermediary distribution channel and prepared to represent not just their own constituents but the entire mortgage intermediary profession. We hope AMI members will want to contribute to the trade body’s work and shape our ongoing agenda by standing for election.”

AMI members who wish to stand for election to the Board and are in any of the above constituencies can request a nomination form by e-mailing info@a-m-i.org.uk. Regional firms are classed as having between 6 and 100 advisers; national firms with over 100 advisers.

22/06/2017 – AMI guidance on cyber security

Recent global attacks, a regulatory focus on cyber risk and General Data Protection Regulation mean now is as important a time as ever for firms to review their cyber security strategy.

AMI has created a factsheet for members which sets out the key areas for firms to consider and potential solutions. We suggest that even firms who have developed solutions in this area check their plans against the sources in our factsheet. Firms should approach cyber risk in a similar way to regulatory risk, in that staff at all levels should have a basic understanding. Cyber risks should also be addressed in firms’ overall disaster recovery plans, which should map the steps that need to be taken in the event of an attack or breach and allocate responsibilities. How a breach is communicated to staff, to the data subjects who might be compromised, and how to deal with regulators and the press should also be covered.

Robert Sinclair, Chief Executive of AMI said:

“The global spread of the WannaCry ransomware should be a wake-up call for businesses to review their cyber security infrastructure, as no sector or type of firm is immune from attacks. This is particularly relevant considering the implementation of the General Data Protection Regulation next May which requires firms to understand how they hold and process their data, with significant fines for any breaches.

Our factsheet should be considered a starting point for members, as the National Cyber Security Centre produces extensive guidance for firms on specific areas. We are including a regular section on cyber security in our monthly member newsletter in which we will feature a different topic and signpost to relevant guidance.”

19/12/2016 – AMI Board Elections 2016

AMI has now completed its election process and the results are:-

  • The Regional Constituency (1 vacancy) – Ray Boulger (John Charcol) is re-elected.
  • The National Constituency (1 vacancy) – Dean Mirfin (Key Retirement Solutions) is re-elected.
  • The Practitioner Constituency (3 vacancies) – Andrew Montlake (Coreco) and John Whyte (The Right Equity Release) are re-elected and Scott Taylor-Barr (Carl Summers Financial Services) is elected.
  • The Mortgage Club Constituency – Stephen Smith (Legal and General) is elected.
  • Network Constituency (2 vacancies) Mark Graves (Sesame) and Peter Curran (Countrywide/Mortgage Next/Mortgage Intelligence) are elected.

Robert Sinclair, Chief Executive of AMI said:

“This process ensures that the membership affirms that it is being properly represented. I would like to thank all those who stand for election which ensures a democratic process. I would also like to express my sincere thanks to Steve Smith of Springtide who is standing down from the Board after many years of service and support. I know this was difficult decision and would like to express my sincere thanks for his contributions over the years and hope that he may return at some time in the future.”

12/12/2016 – FCA launches market study on competition in the mortgage sector

AMI is pleased that the study appears to have more specifically focussed its attention since the feedback statement in May 2016. AMI was and remains strongly supportive of the move to deliver more advised sales as set out in the MMR. This allows the market to be complex and innovative whilst giving the consumer the safety net of professional advice and full regulatory protection. AMI remains wary of those who argue that the regulatory demands stifle innovation, whereas we see them as necessary to ensure the best consumer outcomes.

Robert Sinclair, Chief Executive of AMI said

“We remain very supportive of this review to ensure that the market allows the right product to get to the right customer and ensuring there are not commercial conflicts which are detrimental to consumers. We strongly support the restriction to the first charge residential market and the inclusion in scope of internal product switching. We are hopeful that this review will size and assess the extent of execution only in product switching and whether this might harm consumers in a rising rate environment.

The decision to look at how consumers access information through best buy tables and price comparison websites (PCWs) as well as directly via lender and broker websites and apps is well founded. In addition ensuring there are no soft inducements in the areas of PCWs and even in sourcing systems will ensure that the market is robust.

AMI will support the work on panels and the impact of restrictions, particularly where it is a panel of one. Whilst we do not feel that the current procuration fee payments influence broker advice due to the relatively small differentiations between lenders, it is positive that this will be reviewed. However it is hoped that the team will look at this as having elements of costs substitution in the chain and is not a pure added cost.

We will be working closely with member firms and the FCA throughout the review period.”

07/11/2016 – AMI’s continuing evolution

The Association of Mortgage Intermediaries has undertaken a further Board review to improve its ability to represent the membership, and is able to lobby in the most effective way.  To deliver this we are making a number of changes to the Board and its components.

We are introducing a new membership class for Mortgage Clubs which will be represented on the Board.  Elections for this position will be held shortly.

Shortly after AMI was established as a distinct legal entity it appointed Patrick Bunton as Chairman in January 2013.  This was for an initial term of 2 years, which was renewed by the Board in December 2014.  The Board have asked Patrick if he will retain this position for a further 12 months.  Patrick has kindly agreed to continue as Chairman.

At the same time Stephen Smith of Legal & General has asked to step down from the position of Deputy Chairman.  The Board extends its deepest appreciation for the long service and support given by Stephen over the years.  He has been on the board of AMI since its inception over 12 years ago and has held the position of Deputy almost as long.  We are grateful for all his hard work in promoting and supporting the Association and for standing for election in the above mentioned Mortgage Club constituency.

The Board have decided that we should elect 2 new Deputy Chairmen, and the Board have agreed to appoint David Copland and Martin Reynolds.

Finally our President, The Rt. Hon the Lord Deben, has decided that this is an appropriate time to step down from the AMI Board.  The Board wishes to thank Lord Deben for his vision and support firstly as Chairman and then as President.  He has provided strong and effective leadership and guidance which has greatly assisted the growth and success of AMI.

Robert Sinclair, Chief Executive of AMI said:

“These changes equip AMI for the challenges that lie ahead in dealing with the Mortgage Competition Review, FSCS funding changes and the advent of the Senior Managers Regime.  The Association is committed to working with firms to act in their best interests.”

07/11/2016 – AMI announces Board election timetable

AMI has announced details of its Board elections which will take place in November. As part of being an open and transparent body, which is fully representative of its members and their interests, the period for nominations for certain Board positions has now been opened.  These are part of the process where all Board positions are re-elected on at least a three year rolling cycle, although existing members of the Board may stand for re-election.  This year’s Board elections will take place in the Regional and National firm constituencies, the Network constituency and three of the Practitioner constituencies.  There will also be a vacancy in a new constituency for Clubs.

Any AMI member firm who falls under one of these constituencies can nominate a member of their senior management team to stand for election.  To stand individuals must complete a nomination form and be nominated by an AMI member from within the same constituency.  Nomination forms must be returned to AMI by 18 November.

Should more than one AMI member want to stand for the Board, a contested election will take place.  Those individuals standing will be required to submit a biography and an election manifesto to those constituents eligible to vote.  Ballot papers for a contested election will be sent out by 25 November.

The results will be announced on 12 December.

Robert Sinclair, Chief Executive of AMI, commented:

“The AMI Board plays a vital role for the organisation in providing direction and policy guidance to AMI’s activities. Members wishing to serve as AMI Board members must be committed advocates of the intermediary distribution channel and prepared to represent not just their own constituents but the entire mortgage intermediary profession.  We hope AMI members will want to contribute to the trade body’s work and shape our ongoing agenda by standing for election.”

AMI members who wish to stand for election to the Board and are in either of the above constituencies can request a nomination form by e-mailing info@a-m-i.org.uk.  Regional firms are classed as having between 6 and 100 advisers; national firms with over 100 advisers and practitioners must be members who spend at least 70% of their working week advising customers on mortgages and related needs.

17/08/2016 – AMI research indicates mortgage prisoners still an issue

AMI in conjunction with NMG Consulting has asked brokers about the extent of the mortgage prisoner issue. The FCA indicated in its May 2016 post MMR Responsible Lending Thematic Review that from its work with lenders, that there was no obvious issue.

However the research undertaken by AMI and NMG in July indicates that 86% of brokers believe there is still a mortgage prisoner issue. Of those, a quarter felt that the problem was getting worse, but the remainder felt that whilst there was an issue circumstances were improving.

In order to scale the problem, 76% of brokers have less than 10% of their clients who are prisoners, whilst 18% estimate that between ten and twenty per cent of their clients are mortgage prisoners. 6% of brokers have more than 20% of their clients who cannot get a new deal.

Robert Sinclair, Chief Executive of AMI said

“Despite the assurances from lenders, lender trade bodies and our regulator, we continue to hear evidence for our firms of a continuing problem. Whilst interest rates remain low, the issue is unlikely to surface significantly. However as soon as rates rise we have no doubt that what is a trickling stream will become a flood and the industry will have to address matters.

This covers a range of issues including weak loan to value, prior self certification, interest only, self employed and those with credit blips but a good mortgage payment record. We hope that the supervision teams at FCA begin to take this seriously and look properly at the extent of this issue and whether all lenders are acting in the best interest of all their mortgage customers.”

30/06/2016 – FCA feedback on 2016/17 fee

In responding to this year’s FCA fees consultation, AMI made a series of objections to the proposals. These included:

  • the overall rise in costs
  • the increases in the fees for mortgage and protection firms
  • the addition of consumer buy to let (CBTL) fees which most firms already include in their declared income.

As one of only two organisations to object to the additional CBTL fees, AMI is pleased that the FCA has agreed to remove the CBTL periodic fee and CBTL FOS levy for already authorised firms.  This means that our members will not have to pay an extra cost for an activity they are already carrying out.

The FCA is however intending to increase its periodic fees for mortgage intermediaries as planned.  Despite AMI highlighting the number of FCA staff that should be working on mortgages based on the amount the industry pays, the FCA has again provided no clarification of its costs.  It has simply attributed the increase to implementing the Mortgage Credit Directive.

Robert Sinclair, Chief Executive of AMI said

“We are grateful that the FCA has acknowledged some of the issues AMI raised around the minimum fee.  The FCA has gone some way to reducing the burden on small mortgage brokers by removing the additional CBTL fees.  However the continued inclusion of the consumer credit fee is not insignificant.  AMI fundamentally believes that consumer credit activities should not require mortgage intermediaries to hold a separate permission as they are already accountable under both the broader FCA principles and specific conduct rules.

Although the majority of intermediaries will pay the minimum fee, there will be a significant bill for the largest firms who will bear all of the £1.2 million increase.  We are disappointed that the FCA has failed to give a full justification for the amount being levied on the sector.”

28/06/2016 – FCA business plan and annual fees consultation 2016

Under the cover of BREXIT on Friday 24 June, the FCA issued a handbook notice which advised that they have implemented the new fees rates without providing their usual feedback and policy statement.  In addition this was not advised to stakeholders or overtly published on their website.

This means that firms may be able to now see their actual fees through the calculator, but as we have not been advised – we do not know.  What is certain is that invoices will now start landing on doormats.   We are promised the feedback statement in due course, but when remains a mystery.  We cannot tell if any account has been taken of our submissions.

Robert Sinclair, Chief Executive of AMI said

“The FCA appears to care little for the organisations’ that fund it.  It is no longer able to meet the simple repetitious timetable of fees consultations, as they appear too excited looking for competition issues in markets where little concerns exist.

To slip this out on a busy news day smacks of all that is wrong with a too big to care regulator.  The sooner Andrew Bailey arrives and gets a grip of the organisation the better.”

16/05/2016 – FCA provides feedback on Competition in the Mortgage Sector

AMI has to express its disappointment that after the five year Mortgage Market Review and the two years it has taken to implement the Mortgage Credit Directive, the sector is not to be left alone. Some might applaud the FCA decision to challenge the results of its own MMR, but AMI is concerned that this will only introduce uncertainty into what is still a fragile market. We are struggling to see the need for even a targeted market study, as the bulk of the issues could be addressed by thematic work and supervisory action.

Robert Sinclair, Chief Executive of AMI said

“Following the publication of final MMR rules, when certainty returned to the market, lending has gradually expanded and both consumers and lenders have chosen to do this through the intermediary channel. It is concerning to see lenders continuing to challenge the results of the MMR now through this route, as whilst it has made the process more onerous for some consumers, more now receive good advice with the full protections that this affords. AMI is concerned that the paper does not recognise the difference between a broker who works in the best interests of the customer rather than the lender who is out to shift product.

We are concerned that there is no respondents list so we can see who has contributed to this debate. However it is great news that the FCA has found that the mortgage market is now lending responsibly and that there are no issues with mortgage prisoners. This appears at odds with broker experience and that of the renowned consumer champion Martin Lewis, so no doubt the Chancellor will be assured by the FCA there will be no issues when interest rates rise. AMI considers that there remain underserved groups of borrowers in the areas of, interest only, lending into retirement, self employed, contract workers, foreign currency earners and ex-pats that still need attention if the market is to serve the whole.

AMI will of course work with the FCA to ensure that consumers can have access to effective online tools to educate and enhance their access to the widest market. We will also contribute fully to ensuring that the debate on best lender and best product for each consumer is fully informed. Whilst we have no issue with lenders selling their own products, this cannot be advice in the full sense of the word, as any solution will be from a restricted product set. The Directive set out clear rules around panels and sets out that there must be full disclosure; the fact that a lender is, after all, a one firm panel appears lost in this paper.

We will work to ensure that any conflicts of interest in commercial arrangements are suitably managed and controlled. We are surprised to see this as an issue as we had assumed that firms that had any such concerns would have dealt with them before now. AMI does not see issues arising from the traditional procuration fee arrangement that was accepted as presenting no issues under MMR and is also enshrined within the European Mortgage Directive.”

05/04/2016 – FCA Business Plan and Annual Fees Consultation 2016

The FCA have today released their new business plan and budget including draft fees for the year 2016/17.  The FCA have set out that that they are holding their existing costs “flat”, but mortgage brokers and lenders will see their funding requirement rise as the second charge regime is integrated into the existing regime.

Most categories will see a 1.6% fall in costs, but mortgages have an increased funding requirement of 8.7% leading to a net increase of 7.1%.  This may not be quite as bad as it seems as the FCA is estimating a 10% increase in firms’ declared income so the amount a firm will pay will fall by 2.3% on a like-for-like basis.  The mortgage industry does however keep paying for its success.

This however masks the fact that £3.1m has been added to the costs of mortgage lenders and brokers to supervise the second charge regime.  The total bill for lenders and brokers now stands at £36.8m and AMI still awaits a proper explanation on what is costing this much.

Robert Sinclair, Chief Executive of AMI said

“When the £200 annual fee for holding the Consumer Buy-to-Let permission is added plus the hidden FOS levy, together with £300 minimum annual fee for Consumer Credit – this makes the new bill for the smallest firms look increasingly expensive.  What was £1,000 only two years ago can now be a staggering £1,619 for the same business.

AMI will:

  • continue to challenge these unfair fee increases on behalf of member firms
  • ask for explanations as to what this money is being spent on
  • be responding vigorously to this alleged consultation
  • campaign for amendment to the unfair FSCS funding arrangements that are not included in this consultation.

The mortgage industry has been hit with significant increases over previous years to pay for MMR and the implementation of MCD.  Now that these are complete there is no respite as firms continue to be dogged with higher fees.  The Business Plan makes no special play on mortgages but the costs continue to grow.  No dividend for the investment in new regulation and no explanation on how the 8% increase was calculated or justified to the FCA Board.”

09/07/2015 – AMI response to FCA MMR Advice and Distribution thematic Review

Robert Sinclair, Chief Executive of AMI said:

”This report is a further important milestone in the MMR journey. It sets out with some clarity the things that the industry needs to improve upon and acknowledges areas where we have made good progress. This document gives us more information on the FCA’s expectations that we have been trying to determine throughout the MMR.

AMI recognises that it is critical that all lenders and intermediaries focus on all the lessons to improve the total performance across the industry and ensure the best possible results for customers.

We have long advocated greater clarity in the process between Fact Finding, Advice, Making an Application, Underwriting and all the related administration activities. Sign-posting this to advisers and consumers may improve things. It is also clear that work needs to be done to ensure more understanding that advice is not just about the best price, but is about defining the most appropriate criteria then finding the cheapest within the agreed criteria.

AMI will be working with the CML and IMLA in partnership with its member firms to fully understand this report and engineer the required changes to processes and practice. We will also continue to ask FCA to give us clarity around their expectations.”

25/06/2015 – Consultation in name only

In responding to this year’s FCA fees consultation, AMI made a series of objections to the proposals. These covered

  • the overall rise in costs,
  • the rise in the minimum fee,
  • the increases in the fees for mortgage and protection firms,
  • the scale of the fees for consumer credit authorisation even where no income is allocated, and
  • the addition of consumer buy to let fees which most firms already include in their declared income.

AMI is deeply concerned that despite the FCA receiving a significant number of responses challenging the proposals no meaningful changes have been made.

Robert Sinclair, Chief Executive of AMI said

”The failure of the FCA to accept any of the arguments offered says much about the current mentality of the organisation as it evolves into a competition authority. The industry is expected to pay for this both in terms of cost and continued damage as it will undoubtedly be found wanting as a new landscape is carved by the changing regime.

There appears no appreciation that the fees being added combined with the surprise elements of FSCS levies are imposing costs that challenge the budget management of firms.

AMI regrets that its case has been ignored to date. The arguments we have proffered are no less valid. It appears that they need to be taken to a wider audience in order to be heard.

In addition, we have been asking for more information on the data that underlies the FSCS levies. The FCA is not communicating with us as fully as we would like on this topic

The AMI Board is considering its next actions.”

26/03/2015 – AMI wishes it was only an 8.5% increase in FCA fees

FCA has today commenced its annual consultation on the fee rates it wishes to charge for 2015/16. Mortgage intermediary firms are already receiving interim invoices on this together with interim FSCS fee demands for pensions mis-selling. These will again visit significant increases in costs for firms that will need to be passed on to consumers.

AMI will be responding to this consultation which closes on 18th May 2015 and will be considering if we require more focussed industry action.

Robert Sinclair, Chief Executive of AMI said

“Whilst FCA are headlining an 8.5% increase which is being passed on across the board, this is never quite how it plays out in practice. For the small broker who has paid the minimum fee of £1,000 for a number of years, this is to be increased to £1,084 and they will also have to pay a new levy to undertake consumer buy-to-let totalling £350 to include their FOS levy. On top of this brokers have still to see clarity on whether or not they need a Consumer Credit permission to talk about some historic loans and mortgages raised for commercial purposes.

All of this means that the small broker will see their FCA fees rise by over 50% per annum. In a zero inflation world, with government committed to reducing bureaucratic costs, this is a travesty. AMI wants FCA to clearly justify to mortgage brokers the need for such increases when they carrying on the same business they have always done.

For larger firms we also expect to see their bills rise by more than the published 8.5%, and we will be monitoring the final numbers in June carefully.”

26/01/2015 – AMI sees positives in Treasury implementation of EU mortgage directive

Following the consultation in September 2014, the response issued by the Treasury today indicates that their genuine desire is to minimise the impact on firms and consumers following the excellent work done in implementing the Mortgage Market Review.  The new provisions deliver as much flexibility as is possible within the framework delivered by the Brussels legislation.

Robert Sinclair, Chief Executive of AMI said, “AMI is delighted that Treasury has listened to the voice of the broker and made changes to take brokers out of the scope of the consumer credit regime for unregulated buy-to-let loans.  In addition the clarification on what comprises regulated consumer buy-to-let is positive.

AMI was concerned that the directive risked an interpretation that regulatory responsibilities lay at an individual level for credit intermediaries and appointed representatives.  It has been clarified that all references remain applicable to firms and their principles, rather than moving down to individual brokers.  The Treasury has also ensured that introducer representatives are not to be fully captured under the consumer credit regime.

There will still be huge challenges for FCA, lenders and brokers in ensuring as seamless a transition as possible, due to the tight timescales involved, but AMI is committed to working with the wider industry to ensure consumers are impacted as little as possible.  We await the FCA policy statement and final rules with interest.”

12/01/2015 – AMI appoints new Senior Policy Adviser

The Association of Mortgage Intermediaries has appointed Aileen Lees as its new senior policy adviser.  Aileen will report directly to AMI chief executive Robert Sinclair.

Aileen joins the broker trade body from consumer website MoneySavingExpert.com, where she served as an external affairs and campaigns officer.  Prior to this Lees worked in the corporate pensions sector.

Robert Sinclair, Chief Executive of AMI said:

“AMI is delighted to confirm Aileen’s appointment.  We were very impressed by the quality of applicants and are sure that she will make a huge contribution to the intermediary market and help shape a policy agenda to support the AMI and AFB broker community.”

Aileen Lees, Senior Policy Officer said:

 “I am looking forward to working closely with the mortgage intermediary market and understanding their issues.  The next two years will see more change in the market and I want to ensure that AMI and AFB are well placed to help consumers get the quality advice they deserve.”

02/10/2014 – Countrywide obtains access to HSBC products

As both parties have said this is an important step forward in the development of the mortgage market post the financial crisis and the deployment of the Mortgage Market Review.

Robert Sinclair, Chief Executive of AMI said:

“As both parties have said this is an important step forward in the development of the mortgage market post the financial crisis and the deployment of the Mortgage Market Review. Whist this is a small and tentative step, I am delighted with the commitment from both parties to expand on this. I have no doubt that as HSBC develops it systems it will look to increase distribution through a wider range of partners.

I am delighted to see HSBC recognise the real value of the professional intermediary market.”

22/09/2014 – New Job Opportunity at AMI

Having served 5 years in policy analysis at AMI, Alex Revell is leaving to join the Sector Support team at the FCA as a Senior Associate.

Robert Sinclair, AMI Chief Executive said:

This is the third AMI policy person who has left to join the regulator. I am delighted for Alex who has grown during his time with AMI and know that he will continue to champion the right thing for consumers as he develops his career. Alex will be missed by the whole AMI family, but the knowledge he takes to the FCA will benefit the wider industry.

This also gives us the opportunity to recruit a new senior policy analyst to ensure that the intermediary broker market is professionally represented as we absorb the challenges of the new consumer credit regime and the European mortgage directive.

AMI is interested in hearing from individuals who have a background in compliance, or mortgages, or public policy, who are looking to broaden their knowledge and hone their communication skills.

25/07/2014 – IMLA and AMI publish joint guidance on lender and intermediary relationships

The Intermediary Mortgage Lenders Association (IMLA) and the Association of Mortgage Intermediaries (AMI) have published a joint framework for the governance of lender and intermediary relationships under the new mortgage rules that are now in place following the final implementation of the Mortgage Market Review (MMR) on 26 April.

The framework focuses on shared principles to drive the processes used by lenders in working with their intermediary partners. The aim is to ensure a fair approach to matters including panel suspension or removal so that governance processes are fair, transparent and subject to the appropriate right of appeal.

IMLA and AMI have published the joint statement of good practice to reflect what is currently done within the industry, in order to guide all firms where necessary and ensure mutual understanding, so both lenders and intermediaries can focus on delivering high quality lending and good consumer outcomes.

Peter Williams, Executive Director at IMLA, commented: 

“The intermediary channel is at the core of the UK mortgage market. Our shared aim is to help lenders and intermediaries think about how best to manage their relationships around the difficult area of panel suspension or removal.

Each lender will differ in the detail of its approach, but the same principles apply across the board. The aim of providing clarity within this general framework is to ensure lenders have processes in place which are as fair and transparent as they can be.”

Robert Sinclair, AMI Chief Executive, commented:

“We appreciate the work that has gone into this by our lender colleagues. We are already aware that in negotiating this document, a number of lenders have introduced changes to their procedures. We know that others will complete their reviews shortly. This partnership approach to change is what will continue to make intermediary distribution of mortgages the natural choice of the future.”

29/05/2014 – AMI Annual Dinner speaker announced

The Association of Mortgage Intermediaries is celebrating another year of representing the consumers choice for advice in the mortgage world. We will be holding our AMI Annual Dinner on Thursday 12th June 2014 and for the eleventh consecutive year this will be sponsored by Santander for Intermediaries.

Robert Sinclair, Chief Executive of AMI said: 

“The Dinner, which will be held at The Millennium Mayfair Hotel, Grosvenor Square, London, will be addressed by Frank Gardner, who is the BBC’s fulltime Security Correspondent reporting on events from Afghanistan to piracy off the Somali coast to Arctic challenges. Frank was shot 6 times at close range while on assignment in Saudi Arabia in 2004, left severely wounded and dependant on a wheelchair. AMI and our event sponsors, Santander for Intermediaries are delighted to arrange for our guests to hear from an individual who has looked death in the face and continues to provide challenge and insight on complex issues.”

04/04/2014 – AMI Annual Dinner Date Announced

The Association of Mortgage Intermediaries will be holding our eleventh AMI Annual Dinner on Thursday 12th June 2014. For the eleventh consecutive year this will be sponsored by Santander for Intermediaries.

This event brings together brokers, lenders, politicians, regulators and the press in an informal environment which gives great networking opportunities.

Robert Sinclair, Chief Executive of AMI said:

“The AMI Annual Dinner will be held at The Millennium Mayfair Hotel, Grosvenor Square, a modern venue in the heart of London. Following the success of the event in the last couple of years in moving to more modern venues and introducing a more light-hearted theme, we will be continuing this approach.

I am particularly grateful for the on-going contribution from Santander for Intermediaries, who have given us fantastic support over the years. Their support of the intermediary world continues in this time of change.”

Individual tickets are available to members, as are a very limited number of tables.

Those wishing to book a place should contact Iain Cartlidge at Incisive Media:
Tel: 020 7316 9625
Mobile: 0779 0007612
iain.cartlidge@incisivemedia.com

13/01/2014 – Results of elections to the AMI Board members

AMI has recently completed the annual elections to its Board. As an open and transparent body, which is fully representative of its members and their interests, this election was part of the process where all Board positions are re-elected on at least a three year rolling cycle, although existing members of the Board may stand for re-election.

This has resulted in David Copland and Gemma Harle being re-elected to represent the Network constituency and Martin Reynolds elected to represent Regional firms.

Patrick Bunton, AMI Chairman said:

“The intermediary sector is facing an exciting and challenging period where we will need to have strong and experienced leadership. The regulatory agenda shows no signs of slackening with the European Mortgage Directive and changes to the Approved Persons regime to follow hard on the heels of the Mortgage Market Review. I am therefore delighted to welcome back David Copland and Gemma Harle to represent the Network constituency. I am also pleased to announce that Martin Reynolds of Sandringham Financial Partners was elected to represent the Regional constituency. I look forward to working with them to promote and protect the interest of all our mortgage intermediary member firms.”

David Copland said: 

“I am delighted to be re-elected to the AMI board, having worked with Robert Sinclair and the team to help in shaping the future of intermediary distribution in the UK. I believe that we have one of the most competitive and mature housing markets in the UK in which the intermediary sector plays a large and important part in delivering solutions to the UK consumer. I am ready to serve a new term which will include the implementation of the MMR, and the challenges that the EU Mortgage credit directive will bring.”

Gemma Harle said:

“I am delighted to be able to continue to support AMI in the valuable work they do in representing the intermediary sector and the important role they play in shaping the mortgage market for the future.”

Martin Reynolds said:

“This year will see many changes within the mortgage market, initially with MMR but also European legislation and AMI will play an important part in helping the intermediary mortgage advisers adapt and change. I am delighted to be part of the new Board helping to continue raising the profile of our membership.”

03/10/2013 – AMI support’s AR option for Consumer Credit but questions whether it’s time to address the issue of regulatory duplication

FCA has published details of its proposed regime for consumer credit. Whilst the focus of the document is on the new requirements for consumer credit firms, there are some implications for mortgage brokers due to the requirement imposed on them to hold a consumer credit licence.

The FCA has confirmed that an appointed representative regime will be applied to consumer credit under its regulation of the industry. 

Robert Sinclair, Chief Executive of AMI, said:

“AMI welcomes FCA commitment to allow for an appointed representatives regime to exist for consumer credit activities. The AR proposition is well established across the financial services industry. Those firms that currently act as AR’s for their mortgage business should also be able to do so for related consumer credit activities.

We are concerned that AR firms that currently hold a consumer credit licence will be required to enter the interim permission regime, even though they may be unlikely to become fully authorised, as they are instead able to become ARs for their consumer credit activities.

FCA has provided greater clarity on its proposals for the regulation of consumer credit. However, AMI’s long held view is that the dual regulation of mortgage brokers, resulting from FCA’s regulation and the OFT’s CCL regime, has created an unnecessary regulatory burden on firms. The regulatory transfer process is an ideal time for FCA to tidy up this unnecessary duplication of rules by removing the consumer credit requirements from firms that already hold a mortgage permission.”

08/06/2013 – AMI issues latest Quarterly Economic Bulletin – Q2 2013

AMI has issued its latest Quarterly Economic Bulletin which focusses on the UK Economy, Housing and Mortgage Market.

In this latest review, the gradually improving but generally flat UK economy is assessed, outlining the continuing limited growth prospects for the country constrained by the global situation. The report identifies the potential impact this might have on the government’s debt reduction targets, the new focus on housing as a means of promoting growth in the domestic economy and the impact this will have on mortgage availability and interest rates.

Robert Sinclair, Chief Executive of AMI, says:

“While credit easing and money supply levers are pulled to encourage activity and lending, regulators are bearing down on the banks to increase their capital ratios. The new Financial Policy Committee declared in March that banks need an additional £25bn in capital to cover further losses in their books. This demonstrates the schizophrenia at the heart of policy making. All other things being equal, this means less lending and less profitable banks – not a good way to encourage a return to brisk activity, and at odds with the policies like the extension of the FLS and Help to Buy.

Mortgage fees continue to rise as rates have dropped – the initial fee payable to secure a mortgage product has increased. Moneyfacts calculate that the average fee is now £1,522, the highest in 25 years. Initial arrangement fees are good news for lenders’, allowing profit to be booked on day one. However, the concern is that escalating fees may discriminate against lower end borrowers, who already face an uphill battle to save for both a deposit and the cost of the stamp duty tax. In this environment, advice will be more crucial than ever, and prospective borrowers will need the insight of intermediaries to navigate beyond headline rates to find the most affordable and appropriate mortgage products.”

08/06/2013 – AMI sees lots of positives in Budget

Today’s budget gives more than a shot in the arm to the residential housing market. For those who have voiced concerns on the lack of housing starts and completions, the new “Help to Buy” announcements might well be the steroid drug infusion package that many have been calling for. By using government guarantees to underpin higher loan to value lending, this will assist lenders to offer more of this type of product without it impacting on their capital and liquidity positions.

Robert Sinclair, Chief Executive of AMI, said:

The new higher loan to value guarantees combined with the proposal to introduce government interest free loans for more than first time buyers must give encouragement to house-builders and to those looking to move up the housing ladder. This product which looks like an “imitation” of the Castle Trust product shows a government that has been listening to the market, but may have cut the ground from under that commercial product. The £600k house value limit is higher than we would have expected, as it may have been limited to the £500k Stamp Duty limit.

Of course the costs of these initiatives, if effective, will see an increase in activity levels and therefore be more than off-set by the tax take from Stamp Duty. The lack of any tidying of this tax remains as a key priority for the market, but clearly is still needed to fund initiatives such as these.

On a more parochial level the reduction in employer National Insurance contributions from April 2014, is a massive boost to small firms like AMI.”

08/06/2013 – AMI laments issues in Consumer Credit move to FCA

Today’s announcement and consultations on moving the responsibilities for the Consumer Credit Act from the OFT to the embryonic FCA present the industry with a series of challenges and a missed opportunity.

Robert Sinclair, Chief Executive of AMI, said:

“The proposal to increase the cost of regulation from £10m to £25m adds another layer of expense to business that is already struggling like the rest of the economy. When combined with the higher hurdles that the FCA will impose on firms to reach full authorisation, we will undoubtedly have fewer firms paying these higher costs.

With the truncated 8 week consultation periods on both the Treasury and FSA papers with Easter in the middle, this will make it difficult for trade bodies to fully consider, consult and feedback on all the issues. As these proposals have been some time in the making, this is disappointing.

In setting out the framework now, we will not see the new conduct rules until late in 2013, with a plan to implement on 1 April 2014. This does not leave enough time for firms to absorb the proposals, recognise the risks and react appropriately. Perhaps the choice of All Fools Day is appropriate. The proposed 6 month dual regime is unlikely to be long enough for legal certainty or practical implementation.

An opportunity missed is the silence on removing the need for mortgage broker to also hold the consumer credit permission. As many hold this only to cover simple reviewing or advising on settling unsecured credit, surely this could be rolled into MCOB and avoid many firms who are already authorised by the FSA needing to go through this interim regime process.”

08/06/2013 – AMI issues latest Quarterly Economic Bulletin

AMI has issued its latest Quarterly Economic Bulletin which focusses on the UK Economy, Housing and Mortgage Market.

In this latest review, the stagnating UK economy is assessed, outlining the continuing down-grading of growth prospects for the country in the next few years. The report identifies the potential impact this might have on the government’s debt reduction targets and the connected risk of this blowing the promised economic recovery off course.

Robert Sinclair, Chief Executive of AMI, says, “In spite of negative news on GDP, the employment, price inflation and wage cost numbers continue to impress. Perhaps the negativity on GDP is masking the fact that with interest rates where they are, large number of people still find life very affordable.

AMI shares the CML predictions for much more gross lending in 2013, with further growth in the buy-to let market a strong certainty. Whilst there has been much concern over the plight of the first-time-buyer, and various steps have been taken to address this, we are concerned over the “squeezed middle”. These are owners who are looking to move for the first or second time, but whose equity has shrunk, or with tighter criteria might not even qualify for the mortgage they have today. Unless they can trade up, the market remains congested and subdued.”

02/05/2013 – FCA finds no evidence of systemic mis-selling of Interest-only mortgages

In the FCA guidance consultation on dealing fairly with interest-only mortgage customers and its thematic review report on the maturity of interest-only mortgages, the FCA has clearly identified that customers are responsible for repaying their interest-only loans. The guidance will require lenders to have clear policies and procedures in place to manage mortgages that may not be repaid in full by the end of their term, including a consideration of what options could be offered to assist these types of customers. Lenders must also act to communicate the potential risk of non-repayment to relevant customers early and frequently enough to give customers sufficient time to consider their maturity options.

Robert Sinclair, Chief Executive of AMI, said:

“In this substantial study of the issues surrounding the maturity of interest-only mortgages, the FCA has not found evidence of systemic mis-selling in the residential interest-only market. It has found that the vast majority of consumers who took out these products understood the terms associated with the loan. However, some customers will need support to ensure that they are able to appropriately manage the maturity of their interest-only mortgage.

To ensure that consumers can make the required adjustments to their mortgages, lenders will need to be flexible in the way they consider affordability assessments. It may not be appropriate for consumers who are looking to move to a capital repayment loan, fully or in part, to be assessed through the current affordability models being employed by lenders. Many of these are set to limit new business flows and might not work in the consumer’s wider best interests. The MMR transition rules should be used to assist with this process once they come in to force.

FCA clearly places the onus on the consumer to repay, however lenders must provide support to assist customers who have maturity issues. Intermediaries may be the first point of contact for some customers but ultimately this is a lender issue.”

09/04/2013 – AMI concerned by new FCA fees and costs

For the first time since the concept of the new twin peaks regulatory structure was proposed, we can now to see the true cost to the industry. In announcing their fees proposals, the Annual Funding Requirement of the combined PRA and FCA entities will increase from £560m to £646m. This increase of 15% is made worse by the loss of the off-set of financial penalties, so increasing the amount to be funded by firms to an additional 24%. The impact on firms is shown in the appendix to this release.

Robert Sinclair, Chief Executive of AMI, said:

“The commitment to maintain minimum fees at £1,000 for all directly authorised smaller firms is welcome news. Indeed with the fall in the FSCS levies, the bill for the smallest firms will be much lower than last year. However this should not mask significant increases in the direct costs of the regulator and massive increases for larger firms.

Indeed the FCA bill for all but the smallest firms holding mortgage and general insurance permissions will increase by around 50% versus last years’ FSA invoice. For the very few firms who are dual regulated, the increases will be even greater.

The only saving grace is that the invoices that will land in July will be smaller than last year. This is because the levies for the Compensation Scheme are much less than last year. Whilst some might feel that the new FCA has been saved by the FSCS, I would counsel caution as the continual upward trend in the cost of our regulators must be stopped and a cap put on their funding. They must learn to prioritise and allocate resources accordingly, as they would require the firms they monitor to do.

AMI will be responding vigorously to this consultation. As the regulator appears to have the funding they need, they must be held to account to perform better in protecting consumers and all good firms from those that continue to do damage to our industry. The proposals to review the funding arrangements will give us the opportunity to establish if there might be a fairer way to pay. The mortgage intermediary community presents a very limited systemic risk, which is indemnified by our commitment to FOS and the FSCS. A fairer deal for firms that present the lowest risk is an avenue we need to consider. We need to ensure great value for our hard earned money”

01/02/2013 – SimplyBiz Mortgages Joins AMI

With immediate effect SimplyBiz Mortgages have joined AMI as an Affiliate member.

Martin Reynolds, Chief Executive of SimplyBiz Mortgages commented:

“We are delighted to be joining AMI at a very important time within the mortgage market. We now have the final rules of the Mortgage Market Review and working with AMI we will aim to keep our members fully up to speed. The level of influence AMI have behind the scenes in relation to this and also the continuing challenges from Europe should not be underestimated.”

“We are keen to offer whatever support we can in helping AMI grow and prosper. We will provide regular updates to our 2,700 members on the key issues that affect them.”

Robert Sinclair, Chief Executive of AMI, says:

“The growing influence of AMI is reflected in the regular addition of new firms who support our endeavours. The addition of SimplyBiz Mortgages to the fold brings opportunity and indicates the direction of travel for the industry. As MMR beckons, we are looking to transform the industry into the mortgage advice profession, and firms such as SimplyBiz will assist in moving all firms in that direction. ”

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