What is interesting is that this all started at the FSA mortgage conference, where FSA chairman Lord Turner made it clear that there was lots of conflicting data capable of being interpreted in more than one way. Since then, we have seen a series of vested interest groups take a particular view.
At the Association of Mortgage Intermediaries, we recognise that there have been faults in all parts of the chain. We acknowledge that some brokers may not have demonstrated the highest of standards at all times.
The FSA authorised the firms that they are now taking enforcement action against and lenders themselves failed to recognise when fraud was being perpetrated against them, abetted in some cases by valuers and solicitors.
We also ask for recognition of the fact that those intermediary firms that have fallen foul of the regulator have not been members of the AMI.
The intermediary community comprises a diverse range of big and small firms, who can be either directly authorised or operating an appointed representative system. We need to use the coming months to undertake a more sophisticated analysis of the strengths and weaknesses of these models than we have seen so far.
However, it should be recognised that, in the current structure, the vast majority of firms are well managed, employ robust compliance regimes and are financially strong.
Some lender representatives have indicated that they only produced high loan to value products and abandoned risk-based pricing at the behest of the broker community.
If the broker community were that powerful, I think that the dual-pricing issues of the last year would have evaporated long ago.
I am convinced that the critical faculties of those who matter in this debate see straight through this flawed hypothesis.
The FSA has opened a debate. I for one believe them when they say this is a true consultation. They want to engage, debate and learn. They have avoided the political pressure to rush to regulate.
Self-certification is not banned and we have not had LTV or loan to income limits imposed. Their aim is to create a more robust, sustainable and less volatile market.
We need practical, sensible regulation with robust supervision that roots out those that tarnish the image of the vast majority of ethical, responsible and honest mortgage brokers who serve thousands of customers very well every week.
It is up us as an industry to demon-strate why banning products, constraining LTV or LTI is not necessary. We need to show why we can be trusted by the regulator.
We need to provide evidence that we are capable. We have the trust of the vast majority of people who have sourced a mortgage through an intermediary. That is not an accident and we will fight our corner. With passion but mostly with evidence.
Robert Sinclair is director of the Association of Mortgage Intermediaries