Ray Boulger,senior technical manager, Charcol
The concerns of distinguished chartered accountants surfacing over the weekend that anyone who has taken out a home-reversion scheme could be caught by the new tax on pre-owned assets as set out in this year's Finance Act, resulting in some cases in their income tax liability increasing by thousands of pounds per annum, should be a concern to all financial advisers as well as those with a home-reversion plan.
In future, in order to protect ourselves from possible complaints, as well as including the new mandatory health warning “Your home may be repossessed if you do not keep up repayments on your mortgage” on all mortgage promotions, perhaps we should all include an additional warning along the lines of”If you follow our advice, your financial position at any time in the future could be adversely affected by retrospective legislation.”
Kevin Duffy, managing director, Hamptons International Mortgages Have you ever had the feeling that a sledgehammer is being used to crack a nut?
At a recent social gathering, I polled 20 friends as to whether they were aware of the imminent Government regulation of mortgages. There was one solitary acknowledgement of this.
Is it just me or are there any others out there who have begun to feel that, with no more than 46 FOS-upheld complaints this year, the whole regulation recipe is grossly overcooked?
Alan Dring,head of sales,Standard Life Bank
We, like many others, embarked upon a process of preparation many months ago but many in the introducer community have left it until the 11th hour.
We are close to our distribution and know that 67 per cent will go through directly authorised intermediaries and 33 per cent through appointed reps.
But a lot of providers out there do not have that level of understanding of their distribution and they could struggle.
We are in a state of frantic activity because we do not have a real time KFI capability. We are offering a “master fax” service – in 10 minutes, brokers will get a faxed KFI back from us.
Paul Howard,intermediary sales associate director, Portman Group So here we are – the last week in an unregulated industry.
It is noticeable around the industry how the work rate has moved up yet another gear – amazing, given that we have all been in top gear for some time.
We are experiencing a huge increase in regulation-related queries from intermediaries who are anxious to ensure they are fully compliant come next Monday.
Letters advising of newly acquired FSA registration numbers are flooding in – supplanting the information already received directly from the FSA.
Last week, my sales team were trained in the new systems and processes we are employing and will now demonstrate those services to their business contacts in the weeks ahead.
Clearly, the transitional arrangements, for business written before regulation but received by lenders after October 31, will cause some additional work for all parties involved. Although signed up in an unregulated market, these loans will be regulated and the lenders will need to ensure they have appropriate information from intermediaries when they come to make an Offer. This will entail a degree of to-ing and fro-ing over the next two or three weeks, collecting details such as broker fees charged. Although annoying, this will be a short-term irritation.
Monday will bring the “Big Reveal” as intermediaries, lenders, sourcing systems, clubs and networks lift the wraps on their new regulation solutions.It promises to be a fascinating day.