Let us know what you think of our proposed changes

It’s worth contributing to our consultations as we do change our position in response to strong arguments


This year we will publish several papers on our Mortgage Market Review as we continue our programme of work to reform the mortgage market.

We have already stated how we believe our rules on arrears charges need to change so lenders are more fair to customers, and how the approved persons regime could be extended to the mortgage industry.

Most recently we have published a feedback statement showing what we have heard from brokers, lenders, trade bodies and consumer organisations on the discussion paper we published last autumn that set out our thinking on what should change in the mortgage market.

In general, the responses to the paper were as we expected. There was a consensus that reform was needed but many cautioned us not to over-react or be too intrusive with product or price regulation.

We are taking on board all the responses and will carry on meeting firms, trade bodies and other stakeholders.

There is a lot we still have to get to grips with and there are some areas where opinion differs, as the feedback shows.

One example of this is our proposal to require income verification for all mortgages.

There has been particularly strong support for this move from consumer organisations, smaller lenders, brokers and some trade bodies. Objections have mainly come from larger lenders.

We intend to publish a consultation paper in Q3 2010 that covers this subject and sets out our position on affordability assessments, non-deposit-taking lenders and product regulation.

This will include whether we should ban loans to individuals with multiple high-risk characteristics.

We will then publish another consultation in Q4 on selling standards, broker affordability assessments, professionalism and disclosure.

People sometimes ask why we publish so many consultation papers on the work we are doing. The answer is because the law that set us up requires us to consult with stakeholders before we formulate new policies.

In many ways this is a good idea and we have often changed our initial position after hearing from professionals and consumers during consultation periods.

While we have to recognise that we cannot please everybody we do listen to strong arguments that are put to us, especially if these are supported by meaningful analysis and real-life examples.

With this in mind the consultation on our approved persons and arrears changes – CP10/2 – closes at the end of this month and you can have your say on our ideas through our website.