MORTGAGE COMPLIANCE

Mortgage compliance has never been so high on the Financial Services Authority's (FSA) agenda. This is born out by the Small Firms Regional Assessments, the Supervisory Priorities and the outcomes of the mortgage thematic reviews.

This focus on mortgage firms has led to firms seeking to identify whether any customer redress is appropriate after a Past Business Review (PBR).

The outcome of Past Business Reviews identifies those customers who may have suffered financial detriment as a result of the sales practices of the firm. At this point it is necessary to assess the extent of the detriment and how the customer should be redressed. This process is known as remediation.

It is important to recognise that the remediation process does not necessarily lead to financial redress being paid directly to the customer; it could require the restructuring of existing mortgages, reduction of the loan by payments to the mortgage lender or even financial provisions in case of future circumstances. The process is complex, potentially long and will require careful auditing to ensure that appropriate remediation is followed through to conclusion.

Telos has worked with experienced financial experts to identify the key components to be considered in the remediation process and to provide calculations for financial redress where this is deemed necessary. This remediation process can be employed wherever causation is identified. In some cases there may be an element of customer causation and in these cases any redress may be reduced. Contact us to discuss in more detail how we can help in this critical calculation.

For more information on using a compliance consultancy the following organisations have useful information.

FSA - Using a compliance consultant
APCC - Appointing a consultant
AIFA - Directory of compliance services
AMI - Useful FSA links