There has been recent press comment over the MCCB annual renewal process, which is currently under way, and our monitoring arrangements as regards our fitness and competence requirements, including professional qualifications for mortgage advisers.
These two areas have been erroneously interlinked and some comment has been made that we are not seeking proof of exam qualifications for mortgage advisers as part of the renewal process or at all.
I make the following points in reply:
The MCCB directly registers firms. It does not register individual mortgage advisers.
It is the firm's responsibility to ensure that its sales staff comply with the fitness and competence and all other MCCB requirements. It is likely that firms will retain a similar responsibility for T&C issues under statutory regulation, given the FSA's proposals under CP174.
As we do not register individuals, we would be unable to verify that copy certificates supplied are actually attributable to staff employed by the firm and that mortgage advice has only been given by those individuals.
During the first quarter of 2003, the MCCB has undertaken a comprehensive monitoring programme in respect of our fitness and competence requirements. This programme has included a wide range of monitoring activities, including visits, requests for copy examination certificates from a large sample of firms (in particular, where the firms has only one mortgage adviser and there is therefore no possibility that this person is being supervised) and reviews of firms' supervision regimes. This work will be ongoing, as with all other aspects of code and rule compliance monitoring.
As part of the data coll-ection process at renewal,firms are being asked to provide information on the qualifications obtained by advisers within the firm. This and other data will be used to inform future compliance monitoring activities as part of our risk-based compliance monitoring strategy.
Almost 51,000 individuals met the qualifications req-uirement at December 31,2002 and we remain considerably impressed with the commitment of the industry to raise standards.
Action is being taken against firms in breach of these requirements.