Three months into mortgage regulation and I think that most people would agree that the intermediary and lender landscape looks very similar to what t did before M-Day.We have seen no high-level casualties and very little change to the industry structure, so far. I believe that most of the pain will come through later this year. So far we have seen almost no network consolidation but I am sure that this is yet to come. No one would deny there is an under-supply of appointed representatives in the market to support the number of networks out there. A consequence of this is that we have seen several networks, including the biggest of all, Network Data, increasing their pricing and I think that other networks will follow. Equally, few would deny that the first few weeks of regulation were a difficult time. Some people have defined it as chaotic but I would not go that far. Websites crashed, key fact illustrations which should have looked identical looked very different, agreements which needed to be completed disappeared and so on. Thankfully, I think everyone now has their website log-ins, agreements, contracts and panels sorted out and should be able to submit business easily to the lenders of their choice. I think that KFIs were undoubtedly the most discussed topic before M-Day and there was real concern that lenders would not be in a position to provide compliant versions. There were problems in the first couple of weeks but these were soon sorted and now the process to get a KFI is second nature to most brokers. However, I do not think anyone quite anticipated how different KFIs would look. particularly in their lengths which differ vastly from lender to lender. I do not think the FSA ever dreamt that lenders would be producing KFIs that were more than 10 pages long but KFIs of this length are not uncommon. The outcome is that I think that most brokers prefer to get their KFIs directly from the lender’s websites rather than from sourcing systems. I think many companies or brokers which decided to take the AR route, fearing that being directly authorised would be too expensive and too complicated, are already considering becoming directly authorised. They have realised that they are not really in control of their own compliance or which lenders they can use. Understandably, networks have to gear their compliance requirements and support to the lowest level of their members. Many networks are now finding that they have more people applying for their directly authorised proposition rather than their AR package. The definitions of whole of market by some networks and companies leave a lot to be desired but until the FSA gives a clear indication of what it feel this means, I think consumers are losing out. Similarly, consumers’ definition of independence and the FSA’s definition’s are still blurred and I cannot see how this is bringing clarity to the market. A more topical area where consumers may be losing out is through advertising. Even now, we are seeing ads that are clearly not FSA-compliant and these ads are often aimed at people who are more vulnerable. The six-month grace period was aimed at areas like Yellow Pages where ads are produced months in advance. More ominously, companies’ operating costs are an even more significant issue since M-Day. Most prac- titioners would agree that being a mortgage broker now is a lot more expensive. Professional indemnity cover in some cases has rocketed. The FSA has just announced consultation on its new fee structure and fees are predicted to increase substantially. I do not think that many people realised how expensive regulation would be, both in terms of real cost and the cost of time spent on regulatory issues not spent on business generation or sales. At the business end of things, the whole process to complete the paperwork for someone’s mortgage has increased but it is difficult to give a figure by how much. Making sure that initial disclosure documents and KFIs are issued on time and fully explained is time-consuming and the implications for not doing this are dire. Yet I do not think that at a broker level we have seen the benefits of regulation emerge so far. Some of the measures above may be necessary evils but firms’ training and development schemes should help brokers do their jobs better and I am sure that, in time, consumers and brokers will benefit from this investment in their training. If used positively, regulation can help raise standards. Mortgage regulation has changed the lives of everyone in the industry in some way or other but I am still not convinced that consumers have noticed the difference. The industry has been prescribed too weighty a meal to digest with not enough bite-sized chunks at the outset to allow its metabolism to adjust slowly. Recent evidence of this is that the FSA has just launched an advertising campaign promoting its key facts logo. Personally, I would prefer it if it started on working to ensure that KFIs were a standard length of no more than two pages.
We are all now wearyingly familiar with the dire and ever worsening standards of admin and service from virtually all the once stalwart life offices, in particular on existing business.
Last week’s headline, Lenders to be named and shamed by BM, caused a few raised eyebrows in the industry, not because of the nature of BM Solutions’ latest initiative but because of an overwhelming sense of deja vu.
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The continuing fall-out from the Competition and Markets Authority’s (CMA’s) review, the rise of the private GP and digital engagement will be the primary focuses in the private healthcare industry during 2015, according to Iain Laws, managing director, healthcare and group risk, at Jelf Employee Benefits.
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