From Shaun Godfrey
The publication of CP146 and RAO is extremely welcome because it will give all those firms involved in providing mortgage advice a fantastic opportunity to influence the future of the marketplace. We will be reviewing the 350-page document and asking our membership for their views prior to a formal submission.
However, at first glance, we welcome the FSA proposals as we already support our members in their compliance with the MCCB code and GISC rules.
It is clear that the FSA would like to ensure a seamless transition to the new regime and I am confident that our members will meet all the new rules and pass the 'due credit' process. We are concerned at the suggestions that post-sale information be either reduced or eliminated, as we feel that this could be counter-productive to one of the FSA's core objectives of 'securing the appropriate degree of protection for consumers'. We would want to see some form of 'reasons why' system.
We also feel that the very popular buy-to-let market needs to be brought in to the FSA remit, but maybe under the regulated area, as in many cases these products are sold for investment purposes.
Bankhall Point One are very aware, through CP121 which affects the regulated financial services market, that the FSA does want all intermediaries to respond. It has demonstrated throughout our dialogue that it does listen, given a constructive and balanced approach to the consultation process.
Bankhall Point One