Tackling barriers: The Protection Gap

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

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

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

The Perception Gap

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

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

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

Your January update from AMI Chief Executive Robert Sinclair

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

Deadline reminder for approvers of financial promotions for unauthorised persons

An important update from the FCA on the 6th February deadline for approving financial promotions for unauthorised persons…

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When AMI first reviewed the European Mortgage Directive text, we felt that the sense of the text meant significant change for UK lenders. We were surprised when the FCA indicated that they were not intending to change their rules.

AMI spends significant time looking at the rules that directly impact brokers, and less on the sections that are lender specific – such as the framing of an ERC. When we looked at the rules –

we saw their point, in that the FCA rules were very similar to the MCD requirements – what is different has been UK lender interpretation of them.

Therefore we expect there to be a change in the way most lenders operate their ERC policy over the next few months. We have seen some shift already, but we should expect more. As the rules indicate that the charge should reflect the real cost of breaking the contract, we could still see a flat rate for fixed terms up to 2 years. However for 3 year fixes and longer, we should expect to see tiered ERCs which reduce over the term of the loan. Any structure that does not reflect this risks being challenged, however it is a lender responsibility to ensure they are complying on this topic and is not part of any broker assessment of suitability.


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