The mortgage market has undergone significant change over the past few years. The Mortgage Market Review of 2014 was followed by the Mortgage Credit Directive in 2016, and the competition Mortgage Market Study set to complete in 2017. Several enforcement notices have been issued to firms who have failed to keep up with the changing regulatory requirements. Themes of the moment are vulnerable consumers, fair treatment of existing customers, appropriate use of panels, and responsible lending. In addition, changes in the tax and stamp duty regimes has meant buying a residential property in your own name may now be more tax-advantageous than buying within an SPV for high net-worth individuals. Certainly, we have seen a number of firms looking to acquire the necessary FCA permissions to enable them to enter into regulated mortgage contracts with such clients.
Need help with mortgage regulation?
There are a variety of things we can do:
- Guide you through to authorisation if you are new to the market
- Prepare variations of permission or submit changes to approved persons forms
- Advise on the application of the Mortgage Conduct of Business Rules and any other parts of the Handbook
- Tighten up your responsible lending or vulnerable customers’ policies. Are they applied in practice and delivering the right outcomes? Or we can review any other of your policies
- Develop management information
- Design and deliver compliance monitoring programmes
- Undertake file reviews or formal past business reviews to identify weaknesses in systems and controls
- Carry out a post-MCD health-check – it is better we do it than to wait for the FCA to come knocking
- Assist with prudential compliance matters or submit regulatory returns
- Prepare and deliver training
- As we are on the FCA panel as a Conduct of Business Skilled Person, we can help if you’ve got an s166 Requirement Notice.
Our people have worked in the industry and at the regulator and our membership of the Council of Mortgage Lenders (CML) helps us keep up to date with emerging issues.