Since assuming responsibility for the regulation of Mortgage Intermediaries in October 2004, the FSA has carried out considerable work to assess how the new regulatory framework has been applied in practice. Initial work has concentrated on disclosure requirements under the Mortgage Conduct of Business ("MCOB") Rules, financial promotions, enforcing the perimeter, and thematic work regarding high risk products such as lifetime mortgages and the sub-prime market. Significant areas for improvement have been identified in all these areas and firms have been put on notice that the FSA expect to see improvements. Other related areas of focus include Treating Customers Fairly, self-certification mortgages and payment protection insurance.
In addition to assisting firms with FSA authorisation, there are a number of ways in which we can help firms ensure that appropriate compliance arrangements are in place. We can carry out tailored "Healthchecks" to assess compliance with FSA requirements in all the key regulatory areas, including MCOB; senior management arrangements, systems and controls; complaints; training & competence; and appointed representatives. We can help you define your approach to Treating Customers Fairly by assisting with your gap analysis, providing an independent perspective on strengths and weaknesses of your approach - see under TCF in our "Briefings" pages. We can also provide an on-going support service to help firms ensure that compliance arrangements and procedures remain up to date whilst providing support in relation to regulatory reporting.
We have a number of clients who conduct much of their business via internet channels, whether directly, or as introducers to others through advertising and hyperlinks. This kind of business can raise quite complicated issues, in terms both of regulated activities and the requirements about financial promotions. We can advise on points to watch.