May has been all about the 700 firm suitability review conducted by FCA.Â Too late to do anything about it now!
Running an excellent business is about limiting your objectives and pursuing excellence with the core offering - so said the headmaster of Winchester which is a famously conservative school.Â But it seems FCA are interested in this too as they focus on business models in their annual report, with a clear reference to this in their 700 firm SR review.
Pension transfers are increasingly causing hiccups at PII underwriters â€“ special terms, exclusions, higher excesses and blank refusal.Â IFAC strongly urge you to get our input on your PII submission if it includes pension transfers.Â
Due diligence on brokers:Â reports are coming in of lenders visiting IFAs and mortgage brokers to prove that they have conducted thorough due diligence on their introducer lines.Â Blogs too are full of complaints about the banksâ€™ over bearing due diligence on their introducing brokers.Â It is clear that Nat west have been conducting detailed due diligence by interview with introducers, Bank of Ireland are asking for a very large number of documents to prove the brokerâ€™s efficiency, Halifax want to see brokers at least annually and Lloyds rely on desk based examination.
Permissions regime:Â there are so many complexities to the permissions regime now that there are precious few IFAs who have the same permissions.Â Every minor change must be approved by the FCA, leading to a bureaucratic log-jam that IFAs can never criticize.Â There are countless varieties of mortgage and B2L permissions, investment advice permissions and CCLs continue to confuse the most brilliant compliance practitioners.Â Mortgage practitioners who donâ€™t advise on consumer credit require the permission solely in order to satisfy the providers who will not accept non-ccl applications without those FCA authorized permissions.Â In addition 150,000 people or firms will be authorized this year according to the FCA business plan â€“ more than the population of Slough â€œcome friendly bombsâ€