The Mortgage Market Review: what it means for residential mortgage providers

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "The Mortgage Market Review: what it means for residential mortgage providers"

Transcription

1 Page 1 The Mortgage Market Review: what it means for residential mortgage providers Grania Baird 13 May 2013 From 26 April 2014 new rules for residential mortgage providers will be 'switched on'. Whilst this brings new compliance challenges for providers, there are also opportunities as the definition of 'High Net Worth' mortgage customers in the final rules has been amended to cover more borrowers and the market for interest-only mortgages survives. This Briefing aims to provide an overview of the main aspects of the Mortgage Market Review looking at the new obligations on lenders with a focus on those areas of particular relevance to private banks including: (1) the new rules pertaining to 'High Net Worth' individuals; (2) interest-only mortgages; and (3) bridging loans. The new rules are designed to ensure that going forward borrowers are less likely to take out mortgages that they cannot afford. 'Responsible lending' is key to the reforms. The new rules oblige lenders to: (1) assess affordability; (2) test affordability by reference to rises in interest rates; and (3) offer interest-only mortgages where there is a credible repayment strategy. In every case, lenders must act honestly, fairly and professionally in accordance with the best interests of their customer (MCOB 2.5.A) and the information provided to customers must be 'clear, fair and not misleading' in accordance with Principle 7 and MCOB 2.2.6R. In respect of distribution, the approach which has been adopted is to ban execution-only mortgages for 'interactive sales' (which includes face to face and telephone sales) for most applicants but allow for some exceptions, including for wealthy customers. Where a customer can be categorised as 'High Net Worth', a non-advised sale on an interactive basis will be allowed provided that the customer meets the high net worth criteria and has been warned about the implications of proceeding without advice. The FCA's approach for High Net Worth applicants assumes that customers in this category are better able to afford independent professional advice and to bear changes in interest rates or declining asset values. A. The new obligations on residential mortgage lenders an overview Affordability Going forward, lenders (rather than intermediaries) will be responsible for affordability checks. In all cases this requires that income is verified (self-certification is banned). In addition to new applications, an affordability assessment will be required in respect of existing borrowers where there is a contract variation or a new contract replacing an existing one unless (a) there is no increase in the level of borrowing, and (b) there has been no change to the mortgage contract likely to be material to affordability. What amounts to a 'change' likely to be material to affordability is not defined. Examples are given, such as where the term of the mortgage is extended beyond the borrower's expected retirement age; where one party to the mortgage is removed; or where a customer changes from a repayment to an interest-only mortgage. The exception to this rule is where the additional advance is sought for the essential maintenance and repair of the property and the value of the property will be adversely affected if that work is not done. The FSA (now the FCA) has recognised that there will be situations where the responsible lending rules bite with respect to existing borrowers and the borrower does not have an acceptable repayment strategy. In those cases, in respect of existing borrowers only, the rules allow the lender to apply some flexibility with respect to the application of the affordability rule for a transitional period. Advised Sales From April 2014, the 'default setting' will be that all interactive mortgage sales must be 'advised sales' unless the lender has determined that the borrower is a 'High Net Worth' mortgage customer, a 'professional customer', 1 a 1 A customer who works or has recently worked in the home finance sector for at least one year in a professional position, which requires knowledge of the home finance transactions or home finance services envisaged, and who the firm reasonably believes to be capable of understanding the risks involved in the transaction or transactions contemplated.' A firm must not treat a customer as being a professional customer for the purposes of MCOB unless it has credible evidence that the customer satisfies the definition. See in particular MCOB DR, 1.2.9ER, 1.2.9CR(1) and 1.2.9FR.

2 Page 2 business borrower 2 or where the transaction is limited to rate switching or amending the terms of repayment (providing that the amount of the loan does not increase). Where an individual in one of these defined groups elects to 'opt out' of an advised sale and proceed on an 'execution-only basis' they must expressly confirm that the lender has explained what they are giving up by doing so. IDD and Key Facts Information The present obligation to provide an initial disclosure document is replaced by a requirement to disclose 'key messages' to the customer at certain points and in others to inform the customer 'clearly and prominently'. The trigger points for presentation of the Key Facts Illustration ('KFI') are changed under the new rules in order to reduce 'information overload' for customers. Variations and greater flexibility is permitted to KFI's provided to High Net Worth mortgage customers. Systems and Controls The new rules include strengthened systems and controls to ensure responsible lending including requirements that: (1) lenders retain their 'responsible lending' records for the period of the mortgage; and (2) maintain robust systems and controls generally including in relation to their use of transitional arrangements with: (i) an exceptions policy that forms part of the lender s wider responsible lending policy; (ii) a record of the rationale behind each lending decision made under the transitional arrangements; and (iii) have clear systems in place for management to monitor the application of these exceptions. Capital Adequacy For non-bank mortgage lenders (including firms providing bridging finance), the new rules will introduce enhanced prudential requirements and will demand an increase in the quality of the capital held on a firm's balance sheet (such that 20% of eligible capital should be share capital and reserves, less intangible assets). Residential mortgage providers will also be obliged to ensure that high-level systems and controls are in place to manage liquidity risk. Professional standards Individuals selling mortgages, supervising call centre staff that do this, or designing scripted questions for non-advised sales, will need to hold a mortgage qualification. The new rules include transitional provisions in relation to the time limit for obtaining the relevant qualifications with a long-stop date of 26 October 2016 (see TC 2.1.6R). Those who advise on, sell or oversee the sale of mortgages will also be brought into the Approved Persons regime although there is no set date for implementation of this proposal. B. High Net Worth Individuals As we mentioned in our introduction, the regulator has settled on an alternative regulatory approach where an applicant for a regulated residential mortgage is classified as a 'High Net Worth' mortgage customer. The FCA has concluded that this tailored approach is justified because of the complex nature of their incomes and the likely shortterm nature of the loans (generally five years). Under the new rules, a High Net Worth mortgage customer is a 'a customer with an annual net income of no less than 300,000 or net assets of no less than 3 million, or whose obligations are guaranteed by a person with an income or assets of such an amount'. The new rules allow the lender to exercise discretion when deciding what assets to include for the purpose of calculating if a potential borrower meets the minimum net assets test. Lenders are permitted to include the value of the mortgaged property (minus the outstanding mortgage) in their calculation. In the case of joint applicants, at least one of the applicants must meet the criteria. The income or assets of two or more applicants cannot be added together. That said, where a borrower holds property with another person as 'joint tenants' (rather than as tenants in common), both owners are considered by law to own 100% of the property and so the full value of the property (minus the outstanding mortgage) may be taken into consideration. 2 Where the regulated mortgage contract is made for a business purpose.

3 Page 3 A lender will not be able to use the lighter 'tailored approach' in relation to an applicant until it has suitable evidence that the borrower can be classified as High Net Worth. Where the borrower is an existing customer of the lender, evidence gained during the pre-existing relationship can be used to satisfy this requirement. Alternatively, the lender must obtain a statement confirming the borrower's status from an independent professional adviser (MCOB 1.2.9C). In those cases where a lender has been able to classify a borrower as High Net Worth, it can then choose to apply the tailored MCOBS provisions in respect of its dealings with that customer. Application of the new regime to a borrower is optional: even if a customer has sufficient assets or income to enable them to be categorised as High Net Worth, lenders are entitled to elect whether or not to apply the lighter regime. The overarching 'responsible lending' rule (MCOB R) still applies in the case of High Net Worth mortgage customers such that the lender is required to satisfy itself that the customer is able to repay the advance plus interest. Under the new rules, all lenders must assess whether borrowers will be able to afford the payments under their regulated mortgage contract by reference to the income of the borrower. In making the assessment as to affordability, the lender must consider the borrower's credit commitments, basic essential expenditure commitments, basic quality of living expenses and the impact of fluctuations in interest rates as well as any future changes in the applicant's income or expenditure of which they are aware. Subject to the rule that all mortgage providers must only lend responsibly in every case, with respect to High Net worth customers (in contrast to the granular requirements for mainstream mortgages) lenders can be flexible as to the way in which the customer meets the affordability test. Lenders can take account of net income and/or net assets. Currently, lenders must provide a KFI to a borrower each time they provide information about a product that is specific to the borrower. In respect of High Net Worth borrowers, the new rules include a number of significant changes both to the timing of KFIs and the wording and the information which should be included. C. Interest-only mortgages In the context of interest-only mortgages, the lender must assess affordability on a capital and interest basis unless there is a clearly understood and credible alternative source of capital repayment. In practice this means that interestonly mortgages can still be sold provided that the borrower can show that they have a credible repayment strategy and the mortgage is affordable. The same rules apply whether the customer is a High Net Worth or mainstream borrower (MCOB R MCOB R). Key elements of the new regulatory requirements in respect of interest-only mortgages are that: (1) the lender has included in its responsible lending policy provisions dealing with interest-only mortgages; (2) the policy clearly documents how the lender will satisfy itself that the customer has in place a clearly understood and credible repayment strategy; and (3) so far as it is reasonable to assess at the time, the lender must be satisfied that the borrower's repayment strategy has the potential to repay the capital borrowed as well as any interest that can be expected to have accrued. When making this assessment, the obligation upon the lender is not to predict the future but to make a judgement at the time of underwriting. The new rules explain that acceptable repayment strategies include: (a) regular deposits into a savings or investment product; (b) periodic repayment from irregular sources; and (c) the sale of assets such as another property owned by the customer. Repayment strategies that are unlikely to amount to a credible repayment plan include: (a) an expectation that the property that is the subject of the mortgage will increase in value such that it could be sold in order to repay the sums borrowed; and (b) an intention on the part of the borrower that an anticipated but uncertain inheritance will be adequate to repay the mortgage. Where the customer's repayment strategy is the sale of the property that is subject of the mortgage, factors which the lender should consider include the equity in the property, property prices in the area and (in the case of a lifetime mortgage) the life expectancy of the borrower.

4 Page 4 With respect to interest-only mortgages entered into on or after 26 April 2014, lenders must carry out reviews (at least once during the lifetime of the product), to check that the borrower's repayment strategy is still in place and that it remains reasonable to expect that the strategy has the potential to repay the capital borrowed. Although the precise timing of the review is not set by the FCA, the lender will be required to carry out the review at a stage of the term such that if the repayment strategy is inadequate, there is sufficient time before the end of the mortgage term to allow the borrower to take appropriate remedial steps. Although the requirement for a credible repayment strategy is considered by some commentators to sound the death knell on interest-only mortgages other than as a niche market for High Net Worth individuals, the fact that they survive for such customers is good news for private bankers at least. D. Bridging loans The new rules define a bridging loan as 'a regulated mortgage contract with a term of twelve months or less'. The affordability requirements are the same as those that pertain to interest-only mortgages under the new rules, albeit that there is no requirement for a review. Prospective borrowers will need to provide a credible repayment plan and lenders will have to meet the requirements of MCOB 11 (responsible lending). In the context of bridging finance, the rules which the lender will be bound by include the obligation to assess a customer's repayment strategy. The FCA has made it clear that an expectation that once the customer has obtained the bridging finance their credit status will be sufficiently improved such as to enable them to obtain a longer term regulated mortgage will tend to show contravention of the requirement that the customer has demonstrated an adequate repayment strategy. E. What are the next steps for firms? The FCA has recognised that the Mortgage Market Review will lead to significant changes to the ways in which mortgage lenders do business. Policies and procedures, processes and systems will have to change. With this in mind the FCA has allowed an extended 18-month implementation window: the vast majority of the new rules will come into effect on 26 April Over the next 18 months, all lenders who provide regulated mortgage contracts will need to: (1) check regulatory permissions - in particular consider whether their permission includes "advising"; (2) review the competency of all those impacted by the training and competence requirements; (3) update their standard mortgage on-boarding processes and their templates for regulated mortgage documentation to accommodate the new rules; (4) review and update their Operations Manual in order to reflect the new requirements; (5) lenders with a particular focus on High Net Worth lending should consider whether they wish to have separate processes and template documents in place for borrowers who will be categorised as High Net Worth mortgage customers in order for them to take advantage of the new 'tailored approach'; (6) where affordability checks are to be outsourced (notwithstanding that under the new rules responsibility remains with the lender), the mortgage lender must ensure that the intermediary has adequate checks and record-keeping systems and procedures in place; (7) lenders must ensure that intermediary and employee reward structures are fully compliant with the new rules. 3 All those apart from the new MCOB E in relation to 'mortgage prisoners'.

5 Page 5 Until the new rules are introduced in April 2014, the FCA will continue to supervise by reference to the existing rules. The FCA has, however, indicated that it will be tracking firms readiness for implementation throughout 2013 and all lending firms will be required to submit information regarding their readiness for the new rules. If you require further information on anything covered in this briefing please contact Grania Baird ) or your usual contact at the firm on This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances. Farrer & Co LLP, May 2013

Generic implementation specific

Generic implementation specific Generic implementation specific What can we implement early? Do we have a plan for consumer education? Will we brief compliance consultants? Will lenders be subject to the same advice regime? If firms

More information

MMR lender roadshow Q&As

MMR lender roadshow Q&As MMR lender roadshow Q&As Responsible lending including affordability Can a firm use their knowledge of a profession when assessing income and future changes? Can I build the interest rate stress test into

More information

Mortgages and Home Finance: Conduct of Business Sourcebook. Chapter 11. Responsible lending, and responsible financing of home purchase plans

Mortgages and Home Finance: Conduct of Business Sourcebook. Chapter 11. Responsible lending, and responsible financing of home purchase plans Mortgages and Home Finance: Conduct of Business Sourcebook Chapter esponsible lending, and responsible of MCOB : esponsible lending, and responsible of Section.6 : esponsible lending and.6 esponsible lending

More information

BBA response to FSA CP11/31 Mortgage Market Review: Proposed package of reforms

BBA response to FSA CP11/31 Mortgage Market Review: Proposed package of reforms Lynda Blackwell Conduct Policy Division Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted via email: cp11_31@fsa.gov.uk 30 th March 2012 BBA response to FSA CP11/31

More information

Mortgage Market Review

Mortgage Market Review Policy Statement PS12/16«««Financial Services Authority Mortgage Market Review Feedback on CP11/31 and final rules October 2012 PS12/16 Mortgage Market Review: Feedback on CP11/31 and final rules Contents

More information

largeequityrelease.com EQUITY RELEASE GUIDE Speak to one of our specialists today on 020 3824 0904

largeequityrelease.com EQUITY RELEASE GUIDE Speak to one of our specialists today on 020 3824 0904 largeequityrelease.com EQUITY RELEASE GUIDE Speak to one of our specialists today on 020 3824 0904 CONTENTS What is equity release?... 3 How much money could I raise through an equity release?... 4 What

More information

Briefing Paper on Equity Release

Briefing Paper on Equity Release COUNCIL of MORTGAGE LENDERS Briefing Paper on Equity Release What is equity release? 1. Equity is the difference between any mortgage you may have and the value of your home. Equity release is a way of

More information

CML interest-only toolkit April 2013

CML interest-only toolkit April 2013 CML interest-only toolkit April 2013 Contents 1. An overview of the options for lenders and borrowers 2. Reactive lender contact strategies 3. Proactive lender contact strategies 4. Spreadsheet matrix

More information

MORTGAGE CREDIT DIRECTIVE: UK IMPLEMENTATION. Financial Regulation

MORTGAGE CREDIT DIRECTIVE: UK IMPLEMENTATION. Financial Regulation MORTGAGE CREDIT DIRECTIVE: UK IMPLEMENTATION Financial Regulation Introduction HM Treasury and the Financial Conduct Authority (FCA) have published consultation papers on implementation of the EU Mortgage

More information

Equity Release. Standards for Appropriate Examinations. AES3/011206 Financial Services Skills Council 2006 1

Equity Release. Standards for Appropriate Examinations. AES3/011206 Financial Services Skills Council 2006 1 Equity Release Standards for Appropriate Examinations AES3/011206 Financial Services Skills Council 2006 1 The Standards The Standards contain the following information: 1. The learning outcomes that must

More information

The Mortgage Market Review and Non-bank mortgage lenders is enhanced Prudential Supervision on the way?

The Mortgage Market Review and Non-bank mortgage lenders is enhanced Prudential Supervision on the way? JULY 2010 The Mortgage Market Review and Non-bank mortgage lenders is enhanced Prudential Supervision on the way? Introduction Since the publication of the FSA's latest Mortgage Market Review consultation

More information

Mortgages running into retirement

Mortgages running into retirement Financial Services Authority Mortgages running into retirement Examples of good and poor practice for mortgage lenders Note: This paper discusses the responsible lending policies of mortgage lenders. It

More information

Embedding the Mortgage Market Review: Responsible Lending Review

Embedding the Mortgage Market Review: Responsible Lending Review Financial Conduct Authority Thematic Review TR16/4 Embedding the Mortgage Market Review: Responsible Lending Review May 2016 Embedding the Mortgage Market Review: Responsible Lending Review TR16/4 Contents

More information

Key Rules for Mortgage and Home Reversion Brokers

Key Rules for Mortgage and Home Reversion Brokers Key Rules for Mortgage and Home Reversion Brokers December 2008 Contents 1. Introduction 3 2. Principles for businesses 6 3. Conduct of business rules 7 Financial promotion 7 Initial disclosure 14 Arranging

More information

Certificate in Regulated Equity Release

Certificate in Regulated Equity Release Unit 1: Fundamentals of Equity Release Certificate in Regulated Equity Release Attainment Level knowledge of: K1 Definition of a Home Reversion (HR) plan & alternative methods of equity release/capital

More information

FINAL NOTICE. (2) Principle 7 (communications with customers); and

FINAL NOTICE. (2) Principle 7 (communications with customers); and Financial Services Authority FINAL NOTICE To: The Loan Company t/a Greenhill Finance ( TLC / the Firm ) Of: Saxon House Moston Road Sandbach Cheshire CW11 3AP Date: 29 October 2007 TAKE NOTICE: The Financial

More information

The changing face of non-standard mortgage lending

The changing face of non-standard mortgage lending The changing face of non-standard mortgage lending November 2014 Executive summary While mortgage borrowers have experienced considerable changes since the start of the financial crisis as a result of

More information

European Union Green Paper on Mortgage Credit in the EU. Response from Prudential plc

European Union Green Paper on Mortgage Credit in the EU. Response from Prudential plc 1 General Comments European Union Green Paper on Mortgage Credit in the EU Response from Prudential plc 1.1 We welcome the opportunity to respond to the Commission s Green Paper on Mortgage Credit in the

More information

KEY MORTGAGE INFORMATION & EXPLANATIONS

KEY MORTGAGE INFORMATION & EXPLANATIONS KEY MORTGAGE INFORMATION & EXPLANATIONS THE SOCIETY Within this document reference to we us and our refers to the Society, full details of which are: Tipton & Coseley Building Society, 70 Owen Street,

More information

Mortgage Market Review Data Reporting

Mortgage Market Review Data Reporting Financial Conduct Authority Consultation Paper CP13/2** Mortgage Market Review Data Reporting May 2013 Mortgage Market Review Data Reporting CP13/2 Contents Abbreviations used in this paper 3 1. Overview

More information

Regulatory impact assessment on capital requirements for reverse mortgage loans

Regulatory impact assessment on capital requirements for reverse mortgage loans Regulatory impact assessment on capital requirements for reverse mortgage loans 28 October 2015 2 Agency disclosure statement 1. This Regulatory Impact Statement (RIS) has been prepared by the Reserve

More information

The Use of IFRS for Prudential and Regulatory Purposes

The Use of IFRS for Prudential and Regulatory Purposes REPARIS A REGIONAL PROGRAM The Use of IFRS for Prudential and Regulatory Purposes IAS 39 Examples Anna Czarniecka Financial Reporting Consultant annaczarniecka@tiscali.co.uk THE ROAD TO EUROPE: PROGRAM

More information

Consultation Paper CP11/16 Underwriting standards for buy-tolet mortgage contracts

Consultation Paper CP11/16 Underwriting standards for buy-tolet mortgage contracts Consultation Paper CP11/16 Underwriting standards for buy-tolet mortgage contracts March 2016 Prudential Regulation Authority 20 Moorgate London EC2R 6DA Prudential Regulation Authority, registered office:

More information

A guide to margin borrowing

A guide to margin borrowing A guide to margin borrowing Before you borrow on margin, it is important to review your financial situation, investment objectives, risk tolerance, time horizon, diversification needs, and liquidity objectives

More information

LEGAL & GENERAL NETWORK MORTGAGE ADVICE STANDARDS

LEGAL & GENERAL NETWORK MORTGAGE ADVICE STANDARDS LEGAL & GENERAL NETWORK MORTGAGE ADVICE STANDARDS MORTGAGE ADVICE STANDARDS. 1. INTRODUCTION 2. GENERAL GUIDANCE 3. RECORD KEEPING 4. SCOPE OF SERVICE 5. HAND OFFS AND REFERRALS 6. INITIAL DISCLOSURE TO

More information

Mortgage Market Review Data Reporting

Mortgage Market Review Data Reporting Financial Conduct Authority Policy Statement PS13/12 Mortgage Market Review Data Reporting December 2013 Mortgage Market Review Data Reporting PS13/12 Contents Abbreviations used in this paper 3 1 Overview

More information

Association of Mortgage Intermediaries response to FSA s CP11/31 Mortgage Market Review: Proposed Package of reforms

Association of Mortgage Intermediaries response to FSA s CP11/31 Mortgage Market Review: Proposed Package of reforms Association of Mortgage Intermediaries response to FSA s CP11/31 Mortgage Market Review: Proposed Package of reforms Introduction This response is submitted on behalf of the Association of Mortgage Intermediaries

More information

EQUITY RELEASE GUIDE. Everything you need to know about equity release.

EQUITY RELEASE GUIDE. Everything you need to know about equity release. EQUITY RELEASE GUIDE Everything you need to know about equity release. An informative guide from the equity release specialists The informative guide to equity release... Equity release has come a long

More information

The Role of Mortgage Insurance under the New Global Regulatory Frameworks

The Role of Mortgage Insurance under the New Global Regulatory Frameworks The Role of Mortgage Insurance under the New Global Regulatory Frameworks By Anna Whittingham Regulatory Analyst, Genworth Financial Mortgage Insurance Europe Summary and Overview The introduction of fundamental

More information

CAVENDISH EQUITY RELEASE. The Essential Guide. Equity Release TRUSTED & IMPARTIAL ADVICE SINCE 1985

CAVENDISH EQUITY RELEASE. The Essential Guide. Equity Release TRUSTED & IMPARTIAL ADVICE SINCE 1985 CAVENDISH Equity Release TRUSTED & IMPARTIAL ADVICE SINCE 1985 EQUITY RELEASE The Essential Guide INDEX Welcome to Cavendish Equity Release 3 How can Equity Release be used? 4 Why is specialist advice

More information

Retirement. Providing solutions for your future

Retirement. Providing solutions for your future Retirement Providing solutions for your future ,,,, We firmly believe that retirement is a time to enjoy the rewards of your lifes hard work and having access to the funds to turn your ideas and dreams

More information

Accounting and Reporting Policy FRS 102. Staff Education Note 14 Credit unions - Illustrative financial statements

Accounting and Reporting Policy FRS 102. Staff Education Note 14 Credit unions - Illustrative financial statements Accounting and Reporting Policy FRS 102 Staff Education Note 14 Credit unions - Illustrative financial statements Disclaimer This Education Note has been prepared by FRC staff for the convenience of users

More information

Margin Account Agreement

Margin Account Agreement IMPORTANT TO READ This includes and incorporates by reference the Day-Trading Risk Disclosure Statement and the Truth-in-Lending Statement attached hereto (together, the Agreement ). Acknowledgments and

More information

Promotion of unregulated collective investment schemes and close substitutes

Promotion of unregulated collective investment schemes and close substitutes Promotion of unregulated collective investment schemes and close substitutes The UK has long had a specific regime, which is both complex and restrictive, which has been designed to limit the scope for

More information

Financial Services Authority. FSA CP13/7: High-level proposals for an FCA regime for consumer credit. A Response by Credit Action

Financial Services Authority. FSA CP13/7: High-level proposals for an FCA regime for consumer credit. A Response by Credit Action Financial Services Authority FSA CP13/7: High-level proposals for an FCA regime for consumer credit A Response by Credit Action Background Credit Action is a national financial capability charity (registered

More information

Welcome to. OneFamily

Welcome to. OneFamily OneFamily Lifetime Mortgages 1 Welcome to OneFamily Welcome to our OneFamily Lifetime Mortgages. This brochure acts as an easyto-digest introduction to lifetime mortgages and provides you with a summary

More information

Equity Loans Policy. Local Housing Strategy 2012 2017

Equity Loans Policy. Local Housing Strategy 2012 2017 Equity Loans Policy Local Housing Strategy 2012 2017 May 2013 1 Contents Policy Statement Introduction Background Strategic outcome Lifespan of policy Supplementary Guidance Purpose of loan Eligibility

More information

Mortgages and Home Finance: Conduct of Business Sourcebook. Chapter 8. Equity release: advising and selling standard

Mortgages and Home Finance: Conduct of Business Sourcebook. Chapter 8. Equity release: advising and selling standard Mortgages and Home Finance: Conduct of Business Sourcebook Chapter Equity release: advising and selling standard MCOB : Equity release:.5a Advised sales.5a.1 (1) MCOB.5A sets out standards to be observed

More information

MABS Guide to the Personal Insolvency Act, 2012

MABS Guide to the Personal Insolvency Act, 2012 MABS Guide to the Personal Insolvency Act, 2012 DISCLAIMER: This Guide is for general information purposes only and does not constitute legal, financial or other professional advice. Specific advice should

More information

About us. For more information call us now on 0800 316 2224 or visit www.cleverlending.co.uk

About us. For more information call us now on 0800 316 2224 or visit www.cleverlending.co.uk About us Having come to the market with a wealth of experience behind us, Clever Lending is a second charge master broker focusing on making secured loans more accessible to intermediaries. With the regulatory

More information

Contents. Finalised guidance. Guidance on the Financial Policy Committee s recommendation on loan to income ratios in mortgage lending.

Contents. Finalised guidance. Guidance on the Financial Policy Committee s recommendation on loan to income ratios in mortgage lending. Finalised guidance Guidance on the Financial Policy Committee s recommendation on loan to income ratios in mortgage lending October 2014 Contents 1. Background 2. Summary of feedback received and our response

More information

1 Introduction. 2 Working together

1 Introduction. 2 Working together 1 Working together 1 Introduction In producing this guide, our aim is that the relationships in which lenders and intermediaries are engaged deliver good customer outcomes. Some individual lenders and

More information

FSB invites feedback on residential mortgage underwriting practices

FSB invites feedback on residential mortgage underwriting practices Press release Press enquiries: Basel +41 76 350 8430 Press.service@bis.org Ref no: 38/2010 20 September 2010 FSB invites feedback on residential mortgage underwriting practices The Financial Stability

More information

ASPE AT A GLANCE Section 3856 Financial Instruments

ASPE AT A GLANCE Section 3856 Financial Instruments ASPE AT A GLANCE Section 3856 Financial Instruments December 2014 Section 3856 Financial Instruments Effective Date Fiscal years beginning on or after January 1, 2011 1 SCOPE Applies to all financial instruments

More information

Planning and implementing property investment strategies for your children's long-term benefit

Planning and implementing property investment strategies for your children's long-term benefit Planning and implementing property investment strategies for your children's long-term benefit This is an excerpt from Lawpack s book Property Investment for your Children. To find out more about making

More information

The Straightforward. Consumer IVA Protocol. 2014 version

The Straightforward. Consumer IVA Protocol. 2014 version The Straightforward Consumer IVA Protocol 2014 version Effective from January 2014 1 IVA PROTOCOL Straightforward consumer individual voluntary arrangement hereinafter referred to as a Protocol Compliant

More information

MOMENTUM RELEASE NOTES V9.04

MOMENTUM RELEASE NOTES V9.04 MOMENTUM RELEASE NOTES V9.04 Date : February 2014 Version : 1.0 Author : Sam Farrow CONTENTS MOMENTUM RELEASE NOTES V9.04 1 CONTENTS 2 INTRODUCTION 3 SCOPE 3 General Enhancements... 3 1. Application Management...

More information

Shared Home Investment Plan Limited. because life is worth living

Shared Home Investment Plan Limited. because life is worth living Shared Home Investment Plan Limited because life is worth living About S.H.I.P.? Shared Home Investment Plan Limited (S.H.I.P.) is an Irish company specialising in home equity release plans for the over

More information

Implementation of the EU Mortgage Credit Directive: summary of responses

Implementation of the EU Mortgage Credit Directive: summary of responses Implementation of the EU Mortgage Credit Directive: summary of responses January 2015 Implementation of the EU Mortgage Credit Directive: summary of responses January 2015 Crown copyright 2015 This publication

More information

Is equity release the right choice for you? Protecting yourself If it isn t right for you, what are the alternatives?

Is equity release the right choice for you? Protecting yourself If it isn t right for you, what are the alternatives? Buyer s Guide : Content Page 1: What is equity release? Page 2: Is equity release the right choice for you? Page 3: Protecting yourself If it isn t right for you, what are the alternatives? Page 4: Lifetime

More information

WHAT IS BUSINESS CREDIT?

WHAT IS BUSINESS CREDIT? 1 WHAT IS BUSINESS CREDIT? Why Do I Need Credit? Establishing a good credit rating is an important financial priority for every business. Having good business credit means that owners of businesses can

More information

ALL YOU NEED TO KNOW.

ALL YOU NEED TO KNOW. LIFETIME MORTGAGE LIFETIME MORTGAGES ALL YOU NEED TO KNOW 1 ALL YOU NEED TO KNOW. 2 LIFETIME MORTGAGES ALL YOU NEED TO KNOW CONTENTS 1. IntrODUCTION 2. AbOUT lifetime mortgages 3. FeaturES of our lifetime

More information

Residential mortgages general information

Residential mortgages general information Residential mortgages general information Residential mortgages general information 2 Contents Who we are and what we do 2 Forms of security 2 Representative Example 2 Indication of possible further costs

More information

FINAL NOTICE. 1. For the reasons given in this notice, the Authority hereby imposes on Quick Purchase a financial penalty of 26,600.

FINAL NOTICE. 1. For the reasons given in this notice, the Authority hereby imposes on Quick Purchase a financial penalty of 26,600. FINAL NOTICE To: Quick Purchase Limited t/a Rent My House Back Address: 1 The Spinney 121 Main Road Danbury Chelmsford Essex, CM3 4DL FRN: 522468 Date: 23 October 2015 ACTION 1. For the reasons given in

More information

FSA Consultation CP13/7: High level proposals for an FCA regime for consumer credit

FSA Consultation CP13/7: High level proposals for an FCA regime for consumer credit FSA Consultation CP13/7: High level proposals for an FCA regime for consumer credit Response from the Consumer Finance Association Introduction The Consumer Finance Association (CFA) is the principal trade

More information

BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT. Important information about. Your home loan

BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT. Important information about. Your home loan BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT Important information about Your home loan Contents PAGE 2 Introduction Agreeing a facility 3 Changes to facilities Insurance 4 Pre-conditions This document

More information

Appraisal A written analysis prepared by a qualified appraiser and estimating the value of a property

Appraisal A written analysis prepared by a qualified appraiser and estimating the value of a property REAL ESTATE BASICS Affordability Analysis An analysis of a buyer s ability to afford the purchase of a home, reviews income, liabilities, and available funds, and considers the type of mortgage a buyer

More information

Reverse Mortgage Is it right for you?

Reverse Mortgage Is it right for you? Reverse Mortgage Is it right for you? Reverse Mortgages are being hyped as a tremendous tool for retirement income. This type of mortgage uses part of the equity in a home as collateral. A Reverse Mortgage,

More information

Product Matrix If you have any questions, please call us for free on: 0800 032 95 95

Product Matrix If you have any questions, please call us for free on: 0800 032 95 95 Product Matrix please call us for free f on: 08000 032 95 95 Product Matrix please call us for free f on: 08000 032 95 95 Our USPs Quotes are free and won t affect your client s credit rating The system

More information

APPLICATION FORM. 1. Please read the brochure and the whole of this application form, which has 10 pages.

APPLICATION FORM. 1. Please read the brochure and the whole of this application form, which has 10 pages. APPLICATION FORM managed inheritance SERVICE 1. Please read the brochure and the whole of this application form, which has 10 pages. 2. Next complete pages 2 to 5, signing on pages 2, 4 and 5. Make a copy

More information

Reverse Mortgages. An investment research policy for using reverse mortgages

Reverse Mortgages. An investment research policy for using reverse mortgages Reverse Mortgages An investment research policy for using reverse mortgages Table of contents Table of contents... 2 At a glance... 3 Introduction... 4 What is a reverse mortgage?... 4 Advantages and disadvantages...

More information

1 MINNESOTA STATUTES 2015 47.58

1 MINNESOTA STATUTES 2015 47.58 1 MINNESOTA STATUTES 2015 47.58 47.58 REVERSE MORTGAGE LOANS. Subdivision 1. Definitions. For the purposes of this section, the terms defined in this subdivision have the meanings given them. (a) "Reverse

More information

Lump Sum Lifetime Mortgage Terms and Conditions. Version 1

Lump Sum Lifetime Mortgage Terms and Conditions. Version 1 Lump Sum Lifetime Mortgage Terms and Conditions Version 1 INTRODUCTION Thank you for choosing Hodge Lifetime. We hope that your lifetime mortgage makes a positive difference during your retirement. This

More information

In Debt? Dealing with your creditors Call: 0800 157 7330 or 01257 251319 www.debtproblemsuk.com

In Debt? Dealing with your creditors Call: 0800 157 7330 or 01257 251319 www.debtproblemsuk.com Debtfocus Business Recovery & Insolvency Ltd In Debt? Dealing with your creditors Call: 0800 157 7330 or 01257 251319 www.debtproblemsuk.com Content highlights Before you read this guide in detail, you

More information

Implementation of the Mortgage Credit Directive and the new regime for second charge mortgages, feedback to CP14/20 and final rules

Implementation of the Mortgage Credit Directive and the new regime for second charge mortgages, feedback to CP14/20 and final rules Financial Conduct Authority Implementation of the Mortgage Credit Directive and the new regime for second charge mortgages, feedback to CP14/20 and final rules March 2015 Policy Statement PS15/9 PS15/9

More information

POLICE MUTUAL ASSURANCE SOCIETY. Principles and Practices of Financial Management July 2015. PPFM v16.4

POLICE MUTUAL ASSURANCE SOCIETY. Principles and Practices of Financial Management July 2015. PPFM v16.4 PPFM v16.4 1. INTRODUCTION... 1 1.1. Purpose and History... 1 1.2. Fair and effective management... 2 1.2. Overview... 3 1.3. Principles of Financial Management... 4 1.4. Practices of Financial Management...

More information

Saffron Building Society Mortgages Savings Investments Insurance Loans. Residential mortgage conditions. www.saffronbs.co.

Saffron Building Society Mortgages Savings Investments Insurance Loans. Residential mortgage conditions. www.saffronbs.co. Saffron Building Society Mortgages Savings Investments Insurance Loans Residential mortgage conditions www.saffronbs.co.uk 0800 072 1100 Saffron Building Society Residential Mortgage Conditions (England

More information

Call for inputs on competition in the mortgage sector

Call for inputs on competition in the mortgage sector Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Mortgages Call for Inputs Strategy & Competition Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 18 December

More information

Loan Disclosure Statement

Loan Disclosure Statement ab Loan Disclosure Statement Risk Factors You Should Consider Before Using Margin or Other Loans Secured by Your Securities Accounts This brochure is only a summary of certain risk factors you should consider

More information

Climb Investco, LLC, a Delaware limited liability company. Climb Credit, Inc., a Delaware Corporation

Climb Investco, LLC, a Delaware limited liability company. Climb Credit, Inc., a Delaware Corporation Amended and Restated Final Agreement of the Parties PARTIES Lender Manager Master Servicer School ELIGIBILITY Eligible Assets Eligible Schools TRANSACTION Transaction Term Survival Program Size Funding

More information

GUIDELINES FOR EQUITY RELEASE SCHEMES

GUIDELINES FOR EQUITY RELEASE SCHEMES GUIDELINES FOR EQUITY RELEASE SCHEMES The Conveyancing Committee of the Law Society of Ireland has developed these guidelines in order to assist practitioners when asked to advise on Equity Release Schemes.

More information

HOME LOAN GENERAL OFFER CONDITIONS (Mortgage Broker Introduction) with effect from 14th March 2016

HOME LOAN GENERAL OFFER CONDITIONS (Mortgage Broker Introduction) with effect from 14th March 2016 These Conditions apply to Your Loan. Other terms and conditions are in the Loan Security. When reading these Conditions You will notice the use of technical and legal words that can be identified by their

More information

REPORT 59 Equity release products

REPORT 59 Equity release products REPORT 59 Equity release products November 2005 Executive summary In the last year Australia has seen the rapid development of a range of equity release products, where consumers can obtain current financial

More information

True Bearing Chartered Financial Planners Terms of Business

True Bearing Chartered Financial Planners Terms of Business True Bearing Chartered Financial Planners Terms of Business The Financial Conduct Authority (FCA) is the independent watchdog that regulates financial services. This document has been designed to be given

More information

Complete Guide to Reverse Mortgages

Complete Guide to Reverse Mortgages Complete Guide to Reverse Mortgages Contents I. What Is a Reverse Mortgage? 2 Reasons for taking out a reverse mortgage 2 Differences between reverse and traditional mortgages 2 II. Where to Get Reverse

More information

Equity Release Guide. www.seniorissues.co.uk

Equity Release Guide. www.seniorissues.co.uk Equity Release Guide www.seniorissues.co.uk For more information or to speak to one of our trained advisers please telephone our Senior Issues Team on 0845 855 4411 The Caesar & Howie Group 7/3/2008 EQUITY

More information

HEARTLAND BANK HEARTLAND HOME EQUITY LOAN LOAN DETAILS

HEARTLAND BANK HEARTLAND HOME EQUITY LOAN LOAN DETAILS HEARTLAND BANK HEARTLAND HOME EQUITY LOAN LOAN DETAILS Sentinel Custodians Limited (Sentinel) of Level 1, 87 Hurstmere Road, Takapuna, Auckland 0622 offers you a Heartland Home Equity Loan on the terms

More information

Client Agreement document

Client Agreement document Client Agreement document for Burton and Fisher Financial Services Introduction This document is aimed at providing you with an overview of Burton and Fisher Financial Services and to introduce you to

More information

Version 0.1 Adult Social Care Deferred Payment Policy Issued: April 2015

Version 0.1 Adult Social Care Deferred Payment Policy Issued: April 2015 Adult Social Care Deferred Payment Policy 1 Introduction 1.1 This Policy details how Deferred Payment Agreements (DPAs) are to be operated by Rochdale Council from April 2015. 1.2 When a person enters

More information

197 Ecclesall Road, SHEFFIELD S11 8HW METRO FINANCE HELPING YOU GET THE MORTGAGE YOU WANT

197 Ecclesall Road, SHEFFIELD S11 8HW METRO FINANCE HELPING YOU GET THE MORTGAGE YOU WANT www.metrofinance.co.uk Fourth Floor, Wards Exchange, 197 Ecclesall Road, SHEFFIELD S11 8HW METRO FINANCE HELPING YOU GET THE MORTGAGE YOU WANT ON THE FOLLOWING PAGES YOU WILL FIND INFORMATION TO HELP YOU

More information

All you need to know about the. Seniors Money Lifetime Loan. Information for you, your family and your advisers

All you need to know about the. Seniors Money Lifetime Loan. Information for you, your family and your advisers All you need to know about the Seniors Money Lifetime Loan Information for you, your family and your advisers 1 Contents This brochure from Ireland s only specialist Lifetime Mortgage provider highlights

More information

Equity release. A guide for those considering unlocking the value in their home

Equity release. A guide for those considering unlocking the value in their home Equity release A guide for those considering unlocking the value in their home Purpose Equity release is a big decision that will affect the rest of your life. It will mean giving up full control over

More information

Fairness of changes to mortgage contracts

Fairness of changes to mortgage contracts Financial Conduct Authority Discussion Paper DP14/2 Fairness of changes to mortgage contracts July 2014 Fairness of changes to mortgage contracts DP14/2 Contents Abbreviations used in this paper 3 Foreword

More information

BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT. Important information about. Your home loan

BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT. Important information about. Your home loan BANK OF NEW ZEALAND FACILITY MASTER AGREEMENT Important information about Your home loan Contents PAGE 2 Introduction Agreeing a facility 3 Changes to facilities Insurance 4 Pre-conditions This document

More information

FSA MORTGAGE MARKET REVIEW: PROPOSED PACKAGE OF REFORMS CONSULTATION PAPER. Response by the Money Advice Trust (March 2012)

FSA MORTGAGE MARKET REVIEW: PROPOSED PACKAGE OF REFORMS CONSULTATION PAPER. Response by the Money Advice Trust (March 2012) FSA MORTGAGE MARKET REVIEW: PROPOSED PACKAGE OF REFORMS CONSULTATION PAPER Response by the Money Advice Trust (March 2012) CONTENTS Introduction About the Money Advice Trust 2 A partnership approach who

More information

Section 1715z-20. Insurance of home equity conversion mortgages for elderly homeowners 1

Section 1715z-20. Insurance of home equity conversion mortgages for elderly homeowners 1 Section 1715z-20. Insurance of home equity conversion mortgages for elderly homeowners 1 (a) Purpose The purpose of this section is to authorize the Secretary to carry out a program of mortgage insurance

More information

Client Agreement 1.9.14

Client Agreement 1.9.14 Client Agreement This is our standard client agreement upon which we intend to rely. For your own benefit and protection you should read these terms carefully before signing them. If you do not understand

More information

IVA PROTOCOL Straightforward consumer individual voluntary arrangement

IVA PROTOCOL Straightforward consumer individual voluntary arrangement IVA PROTOCOL Straightforward consumer individual voluntary arrangement Purpose of the protocol 1.1 The purpose of the protocol is to facilitate the efficient handling of straightforward consumer individual

More information

Statement of Policy Deposit Guarantee Scheme. April 2015 Updated July 2015

Statement of Policy Deposit Guarantee Scheme. April 2015 Updated July 2015 Statement of Policy Deposit Guarantee Scheme April 2015 Updated July 2015 Prudential Regulation Authority 20 Moorgate London EC2R 6DA Prudential Regulation Authority, registered office: 8 Lothbury, London

More information

Binding Offer. Foreign Currency Loans Pipeline. Sourcing Systems

Binding Offer. Foreign Currency Loans Pipeline. Sourcing Systems CLICK on a tile for more information To get back here, click on the Halifax logo What is MCD? Binding Offer Second Charge Loans ESIS Reflection Period BTL Regulation Sales Process Foreign Currency Loans

More information

Equity Release Guide

Equity Release Guide A Refreshing Approach to Equity Release Equity Release Guide Are you thinking of Equity Release? Choose The Right Equity Release Nationwide Service All Lenders Available Personal Visits What is Equity

More information

White Paper Presented by Vizolution. The impact of the Mortgage Market Review (MMR) on regulatory compliance

White Paper Presented by Vizolution. The impact of the Mortgage Market Review (MMR) on regulatory compliance The impact of the Mortgage Market Review (MMR) on regulatory compliance How to create a robust audit trail that proves mortgage sales are compliant with the MMR November 2013 Executive Summary The Mortgage

More information

A Professional Approach to Short Term Lending Secured against Land or Property

A Professional Approach to Short Term Lending Secured against Land or Property A Professional Approach to Short Term Lending Secured against Land or Property 2012 Edition A Professional Approach to Short Term Lending Secured against Land or Property Introduction The members of the

More information

Application form Residential Mortgage

Application form Residential Mortgage Application form Residential Mortgage Intermediary details This section requires details of any Broker, Packager, Sub broker, or Network who has an interest in this application. THIS PAGE MUST BE COMPLETED

More information

BROKER AGREEMENT. NOW THEREFORE, in consideration of promises, covenants and agreements hereinafter contain, the parties agree as follows:

BROKER AGREEMENT. NOW THEREFORE, in consideration of promises, covenants and agreements hereinafter contain, the parties agree as follows: THIS AGREEMENT is entered into in the State of California this day of 2006, between Crestline Funding Corporation, hereinafter referred to as Crestline Funding, and, hereinafter referred to as Broker.

More information

Veridian Private Student Loan - Option 1

Veridian Private Student Loan - Option 1 Private Education Loan Application Disclosure Form Page 1 of 6 Veridian Private Student Loan - Option 1 Veridian Credit Union c/o Aspire Servicing Center 6775 Vista Drive West Des Moines, IA 50266-9305

More information

A Guide to Releasing Capital from your Home

A Guide to Releasing Capital from your Home Advice for older people A Guide to Releasing Capital from your Home Advice provided by Advice for older people FirstStop Advice brings together the expertise of some of the most trusted and respected organisations

More information

APRA s Perspective on the Residential Mortgage Lending Market. Submission to the House of Representatives Standing Committee on Economics

APRA s Perspective on the Residential Mortgage Lending Market. Submission to the House of Representatives Standing Committee on Economics APRA s Perspective on the Residential Mortgage Lending Market Submission to the House of Representatives Standing Committee on Economics 18 July 2008 Purpose This submission provides APRA s perspective

More information

Financing and Liquidity Strategies

Financing and Liquidity Strategies Financing and Liquidity Strategies A Morgan Stanley offers you a comprehensive approach to financing and liquidity delivering customized solutions for you that complement your overall investment strategy

More information

A SUPPLEMENT TO ABA BANKING JOURNAL WHITE PAPER DEBT CANCELLATION: THE PREFERRED ALTERNATIVE TO CREDIT INSURANCE

A SUPPLEMENT TO ABA BANKING JOURNAL WHITE PAPER DEBT CANCELLATION: THE PREFERRED ALTERNATIVE TO CREDIT INSURANCE A SUPPLEMENT TO AN ABA BANKING JOURNAL WHITE PAPER DEBT CANCELLATION: THE PREFERRED ALTERNATIVE TO CREDIT INSURANCE Debt Cancellation: the preferred alternative to credit insurance by Bob Reilley, Senior

More information