Most Mortgage brokers rely on their Loan Packager to offer an appropriate secured loan to their customers. With regulatory changes this may need a closer look and when dealing with a complaint The FOS will look at customer outcomes and the part every one played.
Here a few questions to consider:
- Have you done sufficient due diligence on your loan packager and do you receive hard evidence of which loan was offered any why?
- Do you document to your client the reason you have offered / recommended a secured loan and do you review this should the loan offer change later in the process?
- Do you have a clear audit trail of the research and products available - as in the mortgage sales process - to be able to show adequate oversight in the case of a referral or appropriate diligence if selling the loan yourself.
If The FCA applies the full requirements of the OFT in regard to secured loans written after April 2014 brokers need to be able to demonstrate they acted with care, diligence and with the best interests of their clients at heart.
It is a common assumption that little will change on 2nd April until The FCA publishes iot's new guidance on secured loans. Dont forget we already have OFT guidance so expect to be measured by it.
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