repossessions
Applying TCF to repossession sales
With so much to consider in the current environment, lenders must be confident that they are employing asset managers who can help them meet their TCF targets with regard to repossession sales
by
Alison Beech,
business relationship director,
Spicerhaart
Treating Customers Fairly is a
requirement of all FSA-regulated organisations and is an integral element of the processes and procedures carried out by these firms. Since the inception of mortgage regulation the FSA looks to all regulated entities to apply the principles of TCF to both the sale of the financial services product and its ongoing management.
The FSA outlines six main outcomes
from the TCF guidelines to ensure that all firms consistently deliver a service to consumers and that senior management take responsibility for ensuring their company and staff at all levels conform. When considering the subject of TCF many will think of how the principles impact on the sales process, in relation to fees and with regard to borrowers who are in arrears. In reality TCF is fundamental to all aspects of financial services product transactions; and at all stages of the life of the product. Recent record fines for lenders charging fees to borrowers in arrears, which the FSA has deemed to be excessive, have put the spotlight on lenders’ treatment of borrowers who firstly cannot meet their
30 morTgAge inTroduCer JUNE 2010
mortgage payments right through to the last resort action of repossession.
ConfidenCe
With so much to consider in the current environment, lenders must be confident that they are employing asset managers who can help them meet their TCF targets with regard to repossession sales. Some of the six aims are, of course, more applicable than others to a supplier for the provision of repossession sales services. As a responsible supplier we view TCF as integral to the success of the company. Although as asset managers we rarely deal with customers directly, we do our utmost to ensure that our policies and procedures meet TCF guidelines from the point of possession through to the completion of the sale. It is necessary that as asset managers we have a comprehensive system in place involving close co-operation with clients on all aspects of the customer experience. The procedures we operate are fully flexible and unlike many asset managers we don’t employ a “one cap fits all” approach to asset management. By using our experience and knowledge we can adapt the possession process to meet each individual client’s expectations. This can be seen from the flexibility that we demonstrate at an account level by adapting the asset management approach to fit property
type, location, condition and other in- depth historic management information and data we analyse at a local level.
Corporate Culture
One of the most important TCF outcomes, which can be met by all organisations, is creating a corporate culture of TCF. It is important that we have robust procedures in place to ensure that the TCF guidelines are foremost in the minds of our employees when carrying out their day to day activities. We have several methods in place to ensure this. All of our new staff handling possession sales are trained in the principles and application of TCF, and given additional refresher courses on a regular basis. This ensures that every member of the team, at every level of responsibility, is aware of the necessity to treat customers fairly.
Get the best priCe
In addition to staff training, the primary method in which we can ensure customers are treated fairly in the repossession process is through minimising the borrower’s shortfall (the debt that remains when the sale proceeds have been applied to the outstanding mortgage account balance). Getting the best possible price in the shortest possible time is usually key to achieving that goal. With interest continuing to accrue to the loan, a delay
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