The trade body says that the move to statutory regulation by the Financial Services Authority means that every regulated firm must assess its T&C arrangements. It is important to note that the T&C scheme covers more than simply the gaining of qualifications. From a firm's senior managers to its advisers and back office staff, the setting up and management of an effective T&C scheme is essential.
The FSA recognises that each individual firm needs to develop its own T&C regime. The regulator's handbook has some important outlines - but each firm needs to decide how much more is required above the core requirements.
Commenting on the publication of the new guide, Chris Cummings, director of AMI, says: "Every intermediary firm had to confirm to the FSA that it would have a compliant T&C scheme in place by Mortgage Day when they applied to be regulated. This guide is designed to help all AMI members complete their T&C preparations and provide a useful double-check that everything is in place.
"Under the MCCB, the focus of T&C was on passing examinations. However, the FSA is at least as focused on ensuring firms can demonstrate on-going competency.
“This starts with a firm understanding its own business risks, putting a T&C Scheme in place, and regularly reviewing it. A key point for all firms to address on Monday November 1, is – how do we prove our advisers are competent to give advice on mortgages under the FSA's requirements - not those of the MCCB? This Guide will help address just such issues."
The new AMI guide has been designed to help members assess their current T&C situation and determine where improvements are needed. For instance, more emphasis will need to be put on the softer communication skills of advisers. Those who are competent at this will be able to prove their clients have really understood what has been offered to them - and so attract fewer complaints.
The new guide can be down loaded from the website - under publications. Alternatively, copies can be e-mailed to members.