SPML has welcomed the publication of CP146, which it says will help the industry to set out the context within which regulation for mortgage sales will take place post-2004.
SPML in-hosue lawyer Gemma Reece says: “As an extensive and detailed document it will require careful consideration and I'm sure the industry will take the opportunity to make plenty of comment ahead of November 11th.
“After an early glance, two areas were of particular interest. Firstly, the admission by the FSA that changes are to be made to the content of the pre-application illustration (PAI). We think this will be helpful having gone through the process of creating our own PAI as part of theconsultation around CP98. We thought it would ultimately prove unworkable in its previous format and length and are glad to see that further consideration will now be given to this important document so that borrowers, introducers and lenders can hopefully derive best value from it.
“It is also clear that due consideration has been given to acknowledge the differing types of sales processes that are widely in use in the mortgage market. The regulation of advice, if it is to be workable and effective has to reflect the differences between advised sales, non-advised sales using filtering questions and execution only sales. Trying to fitindividual customer's requirements under one descriptive umbrella does not mirror what happens and we welcome the clarity in this area.”