The 98 page Consultation Paper for the Distribution and Disclosure part of the FSA’s Mortgage Market Review has been published with a fanfare of trumpets, only losing it’s place on the front pages because a couple of nice young people decided to get married.
In terms of it’s actual content, (I must admit I am still reading it), there are a few headlines that were pulled out on the initial press release:-
* Replacing the obligation to issue an Initial Disclosure Document to the customer with requirements to clearly and prominently disclose key information about how the intermediary will be paid and the service they offer
* Changing the trigger points for providing the Key Facts Illustration to minimise information overload on consumers and reduce burdens on firms
* A requirement for all individuals that sell mortgages to hold a relevant mortgage qualification ensuring appropriate professional standards across all sales
* Replacing the existing labels used to describe the firm’s service with the Retail Distribution Review’s ‘independent’ and ‘restricted’ labels
* Requiring firms to disclose to customers whether they will consider deals that can only be obtained directly from a lender
To be honest there is not alot wrong with any of this and it is important to make sure that consumers are in no doubt whatsoever as to who is giving the advice and whether they are truly independent or not, in fact whether they are actually getting advice at all.
More on this to come so watch this space…