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Paul McGerrigan: “The need to prepare effectively for the FCA taking the reins in April 2016
How many times a year do you say 'I can't believe it's already..." or "Where does the time go?" I say it a lot…
The reality is it will be Christmas before we know it and then we are only four months until regulation by the Financial Conduct Authority comes into force. So if you are serious about secured loans, now is the time to make your preparations.
Application for mortgage permissions.
If you don't have these already you are going to need them to work in the secured loans market next year. The FCA is welcoming applications from the 20th April onwards so the time has come to get cracking. The sooner the better as there is a lot of work involved.
Interim to Full permissions.
Everyone has been given their 'slot' to complete an application but whilst you are applying for mortgage permissions the FCA has acknowledged that it makes sense to do both together.
Again, there is no time like the present - there is a lot of work involved so the sooner you get started to sooner you will be able to bask in the satisfaction that your application is in.
Processes and procedures post March.
We all know that the way secured loans are going to be administered is going to change significantly. The introduction of the ESIS, a reflection period, a lender offer etc etc. It will take time for these changes to bed in, not just within your business but also with your lending partners. Adapting systems and technology to cope with regulatory change is always a challenge, particularly when you are under time pressures. If you haven't started these conversations internally and with your lenders you should begin now.
In summary, my best advice would be to not get caught at the start of 2016 saying 'I can't believe it's January already - I must start thinking about the impending FCA changes'. It may well be too late by that stage.
Next time, Paul will discuss in greater depth what will be required and expected from secured loan brokers under the new regulatory regime, including the ESIS - the form which must be used to explain to customers the implications of borrowing, in terms of charges and conditions.
By Paul McGerrigan, chief executive of Loan.co.uk
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