The trade body has submitted its response to the Financial Services Authority consultation today and in it argues that there is a strong case for making advice compulsory for all if not some at risk groups such as credit impaired, borrowing into retirement and first-time buyers.
The trade body says the new proposals on appropriateness and affordability might make it difficult for consumers to identify the difference between the two processes.
Other bodies such as the Council of Mortgage Lenders are strongly supportive of maintaining an non-advised route.
AMI says it could support this but only if customers are made aware of the protections they may be foregoing in following this route, such as their right to complain to the Financial Ombudsman Service.
Robert Sinclair, director of AMI, says there is a pressing need for further consultation on the combined elements of the MMR in a single paper, prior to implementation – because of the interconnection between the proposals.
He says: “This is liable to be made more significant by initiatives in Europe, which will impact on some of the earlier proposals, will need amending, thereby causing a domino effect and make certain aspects of the proposals less practical.”
Sinclair says although the intent of the FSA is clear, it is unclear whether firms should be trying to adapt now or wait for the agreed appropriate outcomes.
He adds: “We will welcome clarity on this and what constitutes the clients best interests and how we will maintain a level playing field between tied and intermediated sales and advice. In addition explanations of what constitutes a “quick quote” and how it would be used, together with how “reasonably foreseeable” will be measured would be helpful.”