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Do you expect to see less or more second charge mortgage lenders in 2018?

SimplyBiz: Credit where it’s due

David Golder

Since joining the proud ranks of those regulated by the FCA, you’re likely to have picked up a number of previously unknown phrases and terms; ‘GABRIEL reporting’, for example, or ‘varying your permissions’.

However, there are three little words that the regulator holds – above all others – very close to its heart: ‘treating customers fairly’. Therefore, I’m sure you won’t be surprised to hear that the FCA continues to focus upon areas which can have the most impact on consumers: creditworthiness and affordability.

As you know, affordability is nothing more than appraising whether a customer can afford to repay a debt. Of course, nobody can predict how an individual’s personal and financial circumstances could change in the future, but the FCA is eager to see all firms implement processes through which affordability and creditworthiness must be assessed by the broker or lender based on ‘sufficient information’ obtained from either the consumer themselves or – where necessary – from a database consultation.

More detailed information on this matter can be found in sections five and six of CONC but, as assessing creditworthiness is part of the FCA’s policy on responsible lending, it is an area that it continues to focus upon intently. One of the major difficulties surrounding creditworthiness is that acting in the client’s best interests might sometimes mean being forced to refuse to act in the way requested by that client. It can be a challenging situation, and properly documenting and evidencing the steps you have followed to reach this decision may prove to be invaluable to you; both in regard to the regulator and the ongoing financial health of your customer. As always, you will need to pay close heed to the actions of the regulator, to ensure you’re keeping up with any changes to their policy.

Regardless of the extent of the changes the FCA choose to make to current regulation, working with an organisation like The SimplyBiz Group means that our specialist team keep up with all the changes in the industry so that you don’t have to do it all yourself. The SimplyBiz Group has 15 years of experience in this area, and is perfectly placed to help you keep compliant on an ongoing basis.

If you have any questions on the information in this article, or any other area of regulation or compliance support, please don’t hesitate to get in touch with the Consumer Credit Centre team on 01484 443 424.

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