News Review: Regulation
The fi rst rule of Fight Club
by
Stephen Smith, director of housing and public affairs, Legal & General
Fight Club was on the TV again the other night. Great fi lm, an amazing plot twist and interesting to see how self-destruction can turn into urban anarchy. No parallels with our industry then. There is one line in the fi lm
that I always remember: “The fi rst rule of Fight Club is there is no Fight Club”. It’s been like that with the timetable for the Financial Services Authority’s Mortgage Market Review. The fi rst rule of the timetable is that there is no timetable for MMR. Until a speech to the British
Bankers Association by Hector Sants, chief executive of the FSA on 3rd March, the previous last word on the subject had been from Sheila Nicoll, FSA director of conduct policy, who said at the Council of Mortgage Lenders’ annual conference last November: “We are not rushing this”. Now Sants has said the
FSA will lay out its proposed framework in the autumn of 2011 but that no rule changes will occur before 2012. So we have a while but that doesn’t mean we should fi le our papers and sit back till the autumn.
Whether you are a directly authorised fi rm responsible yourselves for reading, understanding and implementing the proposed changes in your own
business or an authorised representative of a network, it is essential to start to plan now. At Legal & General network
we are now moving from analysis and response to the MMR proposals into an impact and implementation phase. We are working with our key partner lenders to understand their plans so as to provide as soft a landing for advisers as we can. Technology and process
lead-in times for projects such as this are usually longer than 18 months so I’d anticipate that if the proposals in the autumn have wide implications for documentation the FSA will delay implementation well into 2013. To add to this there is also
the EU Credit Directive which has proposed changes to the disclosure documentation required on a mortgage case and, at the earliest, implementation of these proposals is expected to be 2014.
Despite the uncertainty
on timing, mortgage advisory businesses need to plan well ahead since changes for them may be extensive in their impact. Changes may be needed to point-of-sale and record-keeping systems, to recruitment processes and referencing and even to the fundamentals of the business model itself if changes are made to advised / non-advised sales or the marketing of “independence”. Still no timetable, but somehow knowing there will be “no rule changes before 2012” makes me feel it is all a lot closer than we think.
Loan application management software
Improve your efficiency Work smarter, reduce costs Easy financial forecasting Diversify rapidly Powerful reporting
Call 029 2030 1401
www.targetgroup.com
MORTGAGE INTRODUCER APRIL 2011 17
Run your broker business out of the box
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60