Peer-to-peer lending processes – calls for change!
It is often the case in emerging markets where new products are being developed, that regulation follows behind market innovations. For example, driverless cars exist and work, but no one has yet articulated the ‘rules of the road’ that will apply when such vehicles compete for space on our crowded transport system. Another extreme example […]
Retirement Interest Only mortgages – are the risks being mitigated?
We have just hit the first anniversary of the FCA Consultation paper announcing the intention to create a new term, Retirement Interest Only Mortgages [RIOs], and to exclude them from the definition of ‘lifetime’ loans. The paper suggested that RIOs had significantly different risks compared to lifetime mortgages as the former did not feature the […]
Time to end “tick box” complaint handling processes
The FCA has recently published the findings of its review of complaint handling by non-deposit taking mortgage lenders and mortgage third party administrators. The results are far reaching and significantly relate to all regulated firms not just to the sectors initially investigated. Overall, the results were positive, but there are areas where firms need to […]
Senior Manager & Certification Regime comes of age – what next?
It is just over 2 years since the FCA Senior Manager & Certification Regime [SM&CR] was implemented for banks and deposit takers. Since then, the regulator has continued to embed cultural changes and strengthen market accountability with the objective of minimising consumer harm. There were, therefore, no surprises that the recently issued policy statement extending […]
Behaviour and Culture of the Irish Retail Banks – a new Individual Accountability Framework
The Independent recently interviewed the Central Bank of Irelands’ Director General (Financial Conduct), Derville Rowland. The issue of culture in Irish banking institutions was considered at length and Rowland indicated that a culture report would be produced for the Minister shortly – it has since been issued. The report focusses on the behaviour of the […]
Artificial intelligence [AI] in financial services
The FCA has announced details of its successful and catchily named ‘fourth cohort candidates’ in its sandbox. This allows firms to test innovative products in a live environment, while ensuring appropriate protections are in place. The 29 successful firms include businesses ‘testing’ automated solutions across a range of product areas including automated advice and decisioning. […]
Mortgage Arrears – time to focus on policies?
The recent UK Finance arrears and possessions conference highlighted several action points for lenders and servicers. The underlying message, which mirrors current regulator themes is clear; organisations should use the current benign arrears environment to “weatherproof” policies and procedures. We were not surprised to hear the renewed focus. Although current arrears numbers are low and […]
Royal Commission and Risk Reviews
There has been historic misconduct within the Australian banking, mortgage and financial service industries – hence a Royal Commission was formed to consider the issues, causes and make recommendations for regulatory change. The final report has now been issued and the recommendations are potentially far-reaching, especially if regulators around the world consider some of the […]
Credit Creep
As financial markets move through economic cycles the focus of regulators often shifts to ensure current and potential risks are adequately assessed and mitigated against. In the current climate economic cycles are shortening and risks are becoming ‘game changers’ quicker. Anyone close to the PRA will be aware that it has identified three key risks […]
Car Loans – mis-selling exposed?
Since the passing of the deadline for the submission of PPI mis-selling claims, the popular media and trade press have been awash with suggested areas that Claims Management Companies [CMCs] will move into next. Whatever you think about CMCs, it seems that the financial services industry can quite easily provide them with plenty of opportunities […]
