Written on 30/06/2022


FCA approval regime has tightened up, as has been reported elsewhere.  Recent conversations with the HQ of those who govern us has stated in plain English that the FCA now have "a zero tolerance against panel removal."

This means that you get removed from a panel, then your mortgage career is effectively over, unless your current firm or network is willing to keep you on.  

It is known that networks will auto-reject any members who are removed, and so with the "GO DA" option removed, this leaves "join another firm" as the only other option.  But finding “any other firm” willing to take you on is not easy either, particularly when word gets around that there is a new zero tolerance regime.  It is frightening, really, insofar as it is retrospective and without challenge.  In at least one case that IFAC have seen it should be challenged, as there seems to be some misunderstanding about the panel removal.  However challenging the FCA is not for the faint hearted, and really represents your local village football team taking on Manchester City.    Of course there isn't really zero tolerance, because hundreds work in the industry post panel removal, often due to mistakes in identity, because their existing principal supports them.  Sometimes the removal is overturned, sometimes the RI has moved on, often unaware of the panel removal.  Nonetheless, many principals will take note and start to remove members of staff who have had issues in the past.  

If you do get removed from a panel it is critical that this matter is addressed and challenged with the utmost urgency.  The first place to start is by involving IFAC or other third party and showing past audits and file check reports to the lender, as proof of good practice.  

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