Are Customers in Arrears Being Treated Fairly?
Lenders and third party servicers will be interested in the contents of the recent Financial Conduct Authority (“FCA”) consultation paper – which has been published as a prequel to issuing guidance around the treatment of customers in arrears. In June 2010, the Financial Services Authority ruled that lenders must not automatically capitalise arrears. Instead, lenders […]
Asset Sales Continue to Stimulate Market
The buoyant market continues, for the private equity firms who use securitisation as one of their funding sources. High street banks, driven by capital realignment, remain focussed on offloading mortgage portfolios originated in the run up to the financial crisis. Additionally, the UK Government is pressing ahead with its ongoing programme of asset disposals from […]
Senior Managers and Certification Regime (SM&CR) Update
With the legislation over six months old, a review has been commissioned by the Financial Conduct Authority (FCA) and some significant changes have been proposed. The FCA is now seeking feedback on new regulations that will extend the oversight responsibilities placed on senior executives and non-executives at UK banks and insurance companies. A number of […]
Mortgage Market Study and Working Together
There were raised eyebrows recently when the Financial Conduct Authority (“FCA”) announced another mortgage market ‘review’, this one entitled a mortgage market study (“MMS”) which is due to take place in Q4 of 2016. This follows feedback it received when asking for commentary on areas of the mortgage sector where competition may not be working […]
Changing times…
Changes, whether they have been in regulation, oversight or in business practices are inevitable but, on the whole they have been positive and progressive. Enhancements in consumer protection and routes for redress are very good examples. However, we should always ask ourselves whether we have learnt from our past mistakes and made the right changes […]
Independent Reviews – Their Increasing Importance
As can be seen by the recent publication of The Treasury Committee report focussing on the various ‘inquests’ into the failure of HBOS plc, independent reviews of businesses, processes and risk positions are back in the news. The debate has now changed direction, including the resurrection of the idea of splitting the oversight of enforcement […]
Securitisation opportunities v asset risk
2016 has been an interesting and difficult year so far for the securitisation market and bonds are trading at their lowest levels for five years. However, the market is resilient and new re-financing opportunities appear regularly. The ever increasing success of the Peer 2 Peer (P2P) lending platforms is an example. The attraction for the […]
CMC Risk Update
We are aware that Claims Management Companies are facing some real challenges at the moment but there is a further regulatory change that is on the way. We have produced a Risk Update for your information, which focusses on the Senior Managers Regime (SMR). This is the first of what will be a series of […]
Senior Managers Regime (SMR)
The SMR regime came into force on the 7th March 2016 for individuals working in banks, building societies, credit unions and Prudential Regulation Authority (PRA) designated firms. What is not apparent to many is that the legislation will be extended to cover all companies authorised under the Financial Services and Markets Act 2000 (FSMA) by […]