UK Finance arrears update – do you really know what you are holding/buying?
UK Finance has just issued its arrears data for Q1 of 2022. The press release highlights some of the positive aspects of the data, for example, the headline “The total number of customers in arrears with their mortgages continued to fall in the first quarter of 2022”. It also highlights the reduction in total arrears […]
Supporting existing customers
In its parting shot of 2022, the FCA issued a consultation in response to the rising cost of living, outlining draft guidance for firms to support customers in financial difficulty. The urgency of the subject matter was obvious as firms were given less than two weeks to respond. Deteriorating market conditions have been further highlighted […]
Affordability stress tests – should funders be concerned?
While the Financial Policy Committee decision to drop lender affordability stress tests was expected, it is difficult to find articles that support the timing of the decision. When the restrictions were introduced in 2014, the intention was to prevent general loosening of credit assessments with the worry that reckless lending could cause an economic downturn […]
PRA seeks proactivity in managing credit risk
The PRA is telling firms to prepare for a prolonged period of stress. While the recent FCA focus has been the increasing risk of mortgage defaults and the resultant risk to consumer harm and market stability, the PRA is tackling the issue from a slightly different angle. In a recent Dear CEO letter to Deposit […]
Equity release concerns return
The Times recently ran an article that highlighted issues with equity release/lifetime mortgages. These mortgages have been plagued by negative connotations and even litigation ever since the first home income plans appeared in the 1980’s. All subsequent variations of the original schemes have suffered their own issues. However, what made this article more worrying was […]
FCA Consumer Duty focus ramps up
The FCA has issued eight of the sixteen sector-by-sector guidance letters for Consumer Duty. The other eight sectors will receive theirs shortly. We have active clients in fifteen of the sixteen individual sectors, so we know Consumer Duty is exercising their minds. With an implementation deadline due in July 2023, the FCA is being proactive […]
ESG – the need for data
It is already a month since I spoke at the Global ABS, in Barcelona, on the need for transparency of ESG factors within RMBS. Not surprisingly, we still await agreed ESG reporting standards and mandatory disclosures. Talk about turning an oil tanker around? Such a manoeuvre would appear to be a short moment in time […]
FCA/Amigo Loans penalty is a warning to all

The FCA decision to impose a financial penalty of £72.9m, “were it not for Amigo’s financial position” and “the risk to the planned customer redress scheme” should be a stark warning to all lenders. We hear some lenders say “We don’t operate in that market”, but that’s not the point. The FCA has always made […]
Underwriting service levels
We have seen, over the last few weeks, a deterioration in residential and commercial underwriting service levels. Brokers complain that the time from submitting an application to receiving a ‘useable’ mortgage offer is getting longer. Several lenders have temporarily withdrawn from the lending market, suggesting they need to protect service levels. Such tactics are damaging […]
Consumer duty – “it’s not going away”

We know this is on everyone’s agenda and by now firms in sixteen separate financial services sectors will have received tailored FCA guidance. As the July deadline looms ever closer the FCA chief executive, while addressing a Treasury Select Committee, warned that Consumer Duty “will not go away”. At the same time, the regulator has […]