From Monty Burn
Endeavouring to clarify the role of an introducer, the FSA helpline referred me to a HMT mortgage document. HMT states clearly that introducers will be excluded in the activity of 'arranging'.
HMT are saying that introducers are not to be regulated yet the FSA appear to be casting doubt on who can conduct a 'fact-find' by introducing new terminology in 'filtering' questions. Although this appertains to non-advised sales people, it will affect the role of brokers.
The FSA could not say whether 'filtering' questions would be in addition to a standard fact-find or form part of the fact-find. Part 13.4 of the document states that “one problem with the non-advised filtering question process is the likelihood that consumers will mistakenly believe they have received advice because of the similarity of the sales process”. Surely the average consumer can understand a statement such as: “I am not an authorised mortgage adviser. However, the details you provide me with will be used by an authorised adviser in assessing the best type of mortgage for your circumstances.”
As this definition and role will affect sales staff, call centres and lead generation companies it will have a profound effect on most mortgage companies. It is unclear to me whether someone who is currently referred to as an introducer (non-regulated) will be able to conduct a fact-find post-N3. As both the FSA and HMT were in some doubt, perhaps a reader can clarify the position for me.