Implementation of the Mortgage Credit Directive on 21 March 2016 will herald further change for our profession. It will also require mortgage brokers to be vigilant in advance, as the way all lenders will deal with outstanding pipeline cases post-implementation is still not completely clear.
The concern among many of the brokers I meet is that any mortgage business written on the current basis and which has not completed by the implementation date may require additional disclosures under the new rules.
The hope is this can be avoided, with feedback from some lenders suggesting a binding offer will be sufficient to allow the mortgage to continue to completion after 21 March.
Over the coming months, we expect to see more lenders amending their systems to start asking for MCD information, and producing MCD-compliant documentation early in 2016 so even if the mortgage has not progressed to formal binding offer by 21 March there should hopefully be no need to do anything further.
As we approach the MCD implementation date, brokers need to stay vigilant of any changes being made to lenders’ policies and criteria, and understand how their transition processes will work.
Advisers should stay close to their network, support services provider, lender BDMs and the media to make sure they get the information they need in a timely manner and avoid the risk of having to undertake any additional work.
Stephen Gazard is managing director at Sesame Bankhall Group