Response to BofE consultation from MBT

28 February 2022

"We welcome this consultation and any attempt to create a lending environment that is built on true customer affordability whilst maintaining a robust and sustainable approach to risk. Based on our data, taken from live cases processed through the MBT Affordability platform, LTI remains a good measure as an approach to limit the risk that lenders undertake and so it is sensible that this remains whilst the use of stress testing is reviewed. The different ways in which lenders calculate affordability means that this is already a complex area and this complexity will increase if standard stress test rates are removed. However, in this context, complexity is a good thing as it more closely reflects the varied affordability of customers and can result in better customer outcomes. The best way for brokers to navigate this complexity is through a comprehensive affordability platform like MBT Affordability."