Member Update 1st February 2019
Written on 31/01/2019

Quote of the Week

There has never been a better time, nor an easier time, to borrow money. 

We now have the era of 100% loans coming back, with Lloyds offering See headline from the Sun Newspaper on Monday


Under the SMCR within firms the FCA expects every area, activity and function responsibility:

a. to be picked and chosen by the firm?

b. To be spread around the firm?

c. To be allocated to one or more senior managers with no gaps or overlaps?

d. to rest with the CEO or Managing Director?

 Answer is C

Sort your Widget's on BAT

BAT allows you to re-arrange your dashboard, so that you can even get special widgets such as weather and news on the home page.

see diagram of options

ANNUAL MLRO report – All firms to download from BAT and save

IFAC fail on AML reports after FCA interview.

Sweeping change introduced on BAT!

IFAC have been caught out by failing to produce annual MLRO reports for our customers.

This came to light on a recent Anti money Laundering thematic review visit by the FCA.

The format went something like this.



So you use a risk based approach? (oh good!)




Have you filed suspicious activity reports?


No – we haven’t had any suspicious activities.


What are the key issues in the MLRO report and what issues did they highlight.


Not as well documented as it should be….but we did a review.


Were any PEPs found?  


No, we found no PEPs.


Smartsearch have a feature which produces an audit trail….this may save you time….in future.

And my final question….

Have you had to liaise with law enforcement agencies?




So IFAC have hastily put together an Anti Money Laundering Report document onto BAT for you to complete and download for your own firm.

This is a major step forward in self – service compliance!

We urge all IFAs and MGI firms and indeed all other FCA regulated firms, to undertake the brief questionnaire that is required to generate the report. See diagram below:

Reasons for using Twenty7Tec on BAT

With regards to some of our key features these are listed below and are not available with other sourcing systems.

The information below highlights what we do differently to our competitors and makes our system more accurate.

  1. Further advance, re-mortgage and 2nd charge sourcing and comparison
  2. Used by some of the UK's largest networks – Mortgage Advice Bureau, Personal Touch, HLP and lager brokerages such as Knight Frank and Charles Cameron and of course IFAC.
  3. Real-time product updates. No update button.
  4. Criteria based sourcing system. Utilising around 400 pieces of criteria per product to help source the right mortgage.
  5. Compare porting products
  6. Bridging loans 
  7. BTL stress testing in line with PRA recommendations. 
  8. All major mortgage clubs supported. Procuration fees and lender codes included.
  9. Works on any screen size, any internet browser and on any laptop, tablet or phone. One system working seamlessly across all devices.
  10. KFI+ / ESIS and complete Evidence of Research documentation included.
  11. Search results displayed in exceptionally quick time.

For training/demo go to

Collecting debt in the EU post Brexit

With changes afoot in our relationship with the EU it will become even more important to be able to collect outstanding debts from European customers. At present we can use the European Order for Payment as a tool for recovery. It is relatively simple to implement and allows enforcement of debt recovery to be effected in the debtor’s home country. Once the future of our place in Europe is settled provisions for debt collection will need to be clarified.

New process for IFAs / MGIs selling term assurance on indemnity terms

Where your firm are taking indemnity commission and using RI  to do this,  you will now need to state the following to your clients and get the clients to agree it on the phone or by signature or email:

“We are paid xxx commission on this policy, but this commission is paid in the expectation that all the premiums will be paid for a period of XXX months (“the initial period”).   If for any reason you stop the premiums during this “initial period”, the provider will claw back some or a proportion of this commission from us.  We notify you, and you hereby agree by receipt of this form, that we will reclaim that same debt from you as an unpaid commission fee within 30 days of the policy premiums becoming over-due.”

This simple letter above will enable recovery from RI, by linking the RI to the client, and is a key fraud prevention mitigation.

It is a known issue with the FCA that they do not consider this to be TCF, and, if enforced rigidly this statement it is clearly anti-TCF.  IFAC strongly recommend that it is only enforced where RIs are found to be churning policies AFTER leaving your firm.  To use this "client clawback" with a customer who has been recently made redundant would probably risk putting you on the front pages of the local newspaper, and would be unenforceable.  But in circumstances where RI fraud is detected it is a key link between the RI and the client, and should be implemented by firms without delay.

IFAC statement on BAT Document Storage facility

IFAC have had reports of competitor software providers NOT providing information that belongs to the IFA in a timely fashion

The BAT system will provide all uploaded documents for you when you leave. 

IFAC will arrange a bulk download link for you after the contract terminations. 

This is from a separate secure site from which you can log in and retrieve at your leisure the documents previously uploaded.

Your documents belong to you, and to your clients, and will be returned without delay.


Update on BAT:

many firms use Turnover Tab to generate commission reports for their advisers.

From today the commission reports are automatically saved into each adviser profile once that they are generated.


From today firms can create and store ADVISER and STAFF files on BAT.

see diagram below, and use this for critical document storage - including HR files.