Tap into our expertise
We are certainly living in interesting times and are facing multiple, changing challenges, daily. The Financial Services world is headline news and whilst to many these challenges seem new, uncharted and without precedent, we do not agree; we see many parallels with previous times and previous recessions. We have, in the past, joked that our […]
Complaints – root cause analysis
You cannot open a consumer supplement of any newspaper today without seeing predictions of the next ‘mis-selling scandal.’ Since the PPI tsunami receded, commentators have suggested numerous products that the Claims Management Company [CMC] industry may target next. The current focus is on the car finance industry and particularly, the financing of car loans. It’s […]
Later life lending – compliance challenges
The Equity Release Council [ERC] recently launched an independent report titled ‘Later Life Lending: Great Expectations’. Constructively, the report recognises the historic problems of equity release, acknowledging that products such as shared appreciation mortgages and investment backed home income plans “continue to cast a long shadow over the market today”. However, despite the statutory regulation […]
Consumer duty – “it’s not going away”
We know this is on everyone’s agenda and by now firms in sixteen separate financial services sectors will have received tailored FCA guidance. As the July deadline looms ever closer the FCA chief executive, while addressing a Treasury Select Committee, warned that Consumer Duty “will not go away”. At the same time, the regulator has […]
FCA/Amigo Loans penalty is a warning to all
The FCA decision to impose a financial penalty of £72.9m, “were it not for Amigo’s financial position” and “the risk to the planned customer redress scheme” should be a stark warning to all lenders. We hear some lenders say “We don’t operate in that market”, but that’s not the point. The FCA has always made […]
FCA Consumer Duty focus ramps up
The FCA has issued eight of the sixteen sector-by-sector guidance letters for Consumer Duty. The other eight sectors will receive theirs shortly. We have active clients in fifteen of the sixteen individual sectors, so we know Consumer Duty is exercising their minds. With an implementation deadline due in July 2023, the FCA is being proactive […]
PRA seeks proactivity in managing credit risk
The PRA is telling firms to prepare for a prolonged period of stress. While the recent FCA focus has been the increasing risk of mortgage defaults and the resultant risk to consumer harm and market stability, the PRA is tackling the issue from a slightly different angle. In a recent Dear CEO letter to Deposit […]
Supporting existing customers
In its parting shot of 2022, the FCA issued a consultation in response to the rising cost of living, outlining draft guidance for firms to support customers in financial difficulty. The urgency of the subject matter was obvious as firms were given less than two weeks to respond. Deteriorating market conditions have been further highlighted […]
ESG comes of age
For too long there has been a sceptical mistrust in the integrity of some ESG labelled securities. It is not surprising that the term ‘Greenwashing’ has become a word in everyday vocabulary. That term seems to have become more acceptable rather than what is really being called out; “exaggerated, misleading or unsubstantiated sustainability-related claims about […]
Risky mortgage portfolios
We have heard commentators starting to describe some mortgage portfolios as ‘toxic’. While that may sound a bit harsh, we can understand how they may have reached that conclusion. There is no doubt that many borrowers are struggling to service their debt and there is also no doubt that certain categories of product and/or criteria […]
