According to the latest figures, there are about 3,000 intermediaries who currently conduct mort-gage business who have neither applied for direct authorisation or appointed representative status – why not?
“Who are they and what impact will this apparent exodus have on the size of the market and the availability of professional mortgage advice? Time will soon tell.”
Portman Building Society associate director Paul Howard
“This week, much of our compliance department resource have centred on our mortgageforce marketing toolbox, the mortgageforce website and the regulations with regards to stationery and the use of the FSA logo to ensure all our resources for franchis-ees are compliant post-M-Day.
“A process to check financial promotions was developed some months ago but recently put into practice. It was rewarding to see an untested process work with only one minor adjustment.
“A large number of financial promotions have been checked for post M-Day compliance and compliance department findings reported to the sales director, detailing the areas of potential non-compliance, the reasoning for the noncompliance and suggested amendments.
“The site is also in the pro-cess of being professionally reviewed but having many links embedded in it, the task has proved to be more time consuming than first envisaged.
“We are finalising another fact sheet to inform franchisees how they may use the FSA logo, and what regulatory statements are required to be used in each branch's stationery.”
Mortgageforce managing director Rob Clifford
“Principals are still telling their ARs they can access all mortgage clubs post-regulation. Clubs will have to have an agreement with the principal firm to achieve this so ARs must check this agreement exists if they want to access the exclusives on offer from clubs.”
Mortgage Intelligence managing director Sally Laker
“Well, here it comes. Only eight weeks to go before M-Day. Most of the interested parties are worrying about what will happen, how many changes to processes need to be made and will the various systems be able to cope.
“Obviously, all advisers will need their FSA permission to advise and be ready with the upgraded quotation systems and initial disclosure documents. However, in my opinion, and more importantly, it should be business as usual.
“Surely, although chan-ges in paperwork and literature are needed for compliance, most of us will continue to feel that the most important area of advising continues to be the advice itself. Discussing client needs, creating solutions and ensuring that the client knows what they've got and how much it is costing them must remain central to the process.
“Don't misunderstand me, being compliant must be a given in this new era but for those who embraced the mortgage code as central to the advisory process, this transition should be much less of a burden.”
Hill Martin mortgage director Steve Smith
“As the FSA has progressively understood more about the functions of a packager they have become increasingly uncomfortable that many packagers were going to be outside the regulatory net.
“This may partly relate to the disclosure of lender payments but because the FSA has moved goalposts at the 11th-hour packagers who decided they did not need authorisation have been put in a very difficult position.
“As a result the lenders and intermediaries who use packagers need to assess whe-ther any such business might pose regulatory risk.”
Charcol senior technical manager Ray Boulger