Consultant Zone

Mortgage Charter Independent Oversight

Mortgage Charter Independent Oversight

The FCA has released its first report analysing the impact of the Mortgage Charter. Launched exactly a year ago, the Charter received some negative industry comment, with a number of lenders suggesting that they already had robust forbearance measures in place and it wasn’t needed. However, on any measure, the FCA data shows positive consumer […]

FCA complaints – a worsening picture

Increasing numbers of complaints, and the lack of real resolution by firms, is not new news, but regulators are becoming impatient for change. After years of TCF and more recently Consumer Duty implementation, it is not surprising that they are questioning when they will see improved outcomes. So why are regulators becoming increasingly tired with […]

Another FCA warning shot

The most recent FCA ‘strategy letter’ on consumer lending is one of the most detailed we have seen, and it focuses on three portfolios; high-cost lending, mainstream consumer credit lending and credit unions.  This is an unusual step for the regulator, as it normally issues separate letters to each portfolio.  However, on this occasion there […]

Regulators warnings on debt collection

A quartet of regulators, FCA, Ofgem, Ofwat and Ofcom have recently reaffirmed their joint commitment to increasing standards in debt collection activities. Their update comes as part of Debt Awareness Week 2024 and follows on from a letter they jointly published in June 2023, which set out their shared expectations as to how firms from […]

Closed books and Consumer Duty

In a recent speech, the FCA warned firms to focus on providing fair value in closed mortgage books, defined as mortgages that were sold before 31 July 2023 and that have not been marketed or sold to new customers since.  The FCA said, “We know many firms have applied their laser focus on open book […]

UK RMBS is alive and well

We have noticed recent trade press commentary stating “UK RMBS is back”.  Clearly positive news, but in our view, it has never been ‘away’.  To be clear, when commenting on UK RMBS we need to distinguish between, and consider the position of, ‘non-bank’ and ‘bank’ providers. Certainly, the involvement of non-bank lenders has been consistent […]

GAP insurers now under the spotlight

The motor finance world is feeling the regulatory heat right now.  As previously reported and commented on, PCP plans have been heavily scrutinised, with hidden commissions being at the top of the ‘must do better’ list.  While the FCA review remains in progress, we now see that 80% of Guaranteed Asset Protection firms have agreed […]

Motor finance challenges

This is not the first time car finance arrangements have been the subject of one of our updates.  Less than 6 months ago we said, “three motor finance firms are facing a class action in respect of overcharging…..the excessive interest claims are eye-wateringly large and if Courts follow the PPI ‘Plevin’ precedent, many more firms […]

Spotlight on directors

We are only a couple of weeks into 2024 and the year is already throwing up governance, risk and compliance challenges for individual directors and senior managers. The downside risk of falling asleep at the wheel, or knowingly acting recklessly, has been brought into focus by two high profile and expensive actions against individuals in […]