This week's article takes a break from looking at the final rules. With the launch of the FSA's dedicated mortgage and general insurance contact centre and application form it is useful to spend a little time examining what's going on and what you need to do about it.
The contact centre went live at 2.30pm on November 3. The FSA met its pledge to launch the centre in early November and logged over 50 calls before the end of the day. So what will the contact centre do? The FSA has said that it can be used to:
Register for an application pack
Answer questions on the application process
Handle complex queries.
The contact centre can be reached on 0845 605 5525. Alternatively you can register for an application pack using the FSA's website www.fsa.gov.uk/mgi In the early days it is likely that call volumes will be high so it may be best to register online. If you are considering direct authorisation you can call the contact centre and receive some straightforward information about the process. You should also call them to register for an application pack. It's important to note that this is simply making an enquiry, not officially applying for authorisation.
The FSA has said that it expects many intermediaries to apply for an application pack as well as actively consider the appointed representative route. It makes sense to at least register for the application pack and look at what turns up. Paper application packs will be available in mid-December so if you haven't received a pack a week or so after registering don't worry, it will probably be well into December before it gets to you (bearing in mind the Christmas post).
The online application forms will be available in January. If you've registered for a pack online you will receive your log on activation code via email in late January 2004. If you do not receive this code by the end of January, you should call the contact centre.
Meanwhile a sample of the application form can be seen on the FSA website at www.fsa.gov.uk/mgi/sampleform or at the AMI website www.a-m-i.org.uk Turning to the sample forms published by the FSA, it's worth having a look through them. They are:
HSF 1 – information to be collected about the firm
HSF 2 – information needed for approval to perform a controlled function and information to be submitted to be an individual controller If you are already regulated by the FSA you should not complete these forms – specific forms for you can be found on the FSA's website (www.fsa.gov.uk/pubs/other/application_pack) or by phoning 0207 066 3954.
We'll spend more time next week looking through the forms in detail but it's worth noting a few points now.
The FSA is still to publish the appendices. These are not part of the sample pack and most firms will need to complete them
The forms are mostly tick-box but you will need to do some work before starting to complete them
As well as specific questions, the FSA does offer some guidelines. The FSA's contact centre can also answer some questions and AMI members can contact us for guidance.
On a different note AMI is pleased to see that the FSA listened to the industry and has amended its proposals regarding business plans. The FSA had originally stated that every firm must provide a regulated business plan with its application. AMI lobbied for a change in this position as it would have placed extra costs on firms and added to the application bureaucracy. We queried how much information the FSA would actually receive from smaller firms' plans.
The FSA has now stated that firms with an annual income of £0-£1m do not need to submit a regulated business plan.
This change alone has saved many mortgage intermediaries more than the cost of joining AMI. Stand up and be counted. Join AMI today.
Charles Gooding – AMI chairman
Q: What is 'arranging'?
Arranging a regulated mortgage contract involves any of the following activities:
Making arrangements for someone to enter into a regulated mortgage contract as a borrower
Making arrangements for a borrower to vary the terms of their existing regulated mortgage contract
Making arrangements so that someone who participates in the arrangements can become a borrower. The FSA has said that arranging can include activities which do not directly bring about a mortgages and accepts that this covers a wide scope.
The final rules provide details on these matters for those who are looking for more specific information than we can give here and the FSA contact centre can now also answer specific queries.
Remember, it will be a criminal offence to carry on any of these activities without being directly authorised or an appointed representative of an authorised firm.