Laurenti was the director of IMAS and solely responsible for ensuring that all activity at the firm complied with FSA standards.
During its investigation, the FSA found that Laurenti had failed to implement appropriate systems and controls leading to a catalogue of errors. These included:
• Submitting multiple mortgage applications for eight customers containing inconsistent personal and financial information;
• Failing to gather adequate information about his customers in order to make informed decisions about their mortgage needs;
• Recommending mortgages to customers without first assessing their affordability; and
• Failing to maintain up to date customer records, leading to the submission of mortgage applications containing inaccurate information
The FSA also found that Laurenti had a residential mortgage on a property in Liverpool, rented it out for two years, but did not submit “a consent to let” application form seeking permission to do so from his mortgage lender.
As a professional mortgage intermediary Laurenti should have known to submit an application to the lender to let his property but he failed to do so for two years. All these failings arose from Laurenti’s lack of competence and capability.
Laurenti agreed to settle at an early stage of the FSA’s investigation and therefore qualified for a 30% discount. Were it not for this discount, the FSA would have imposed a financial penalty of £20,000.
Mukhtar Khan trading as United Finance and Insurance Services has been banned for not being fit and proper on competence and capability grounds.
In June 2010 the FSA carried out a Treating Customers Fairly assessment at UFIS. During the assessment it became clear that Khan lacked knowledge of the TCF principles and that no action had been taken to ensure all areas of the business were delivering fair outcomes for customers.
Khan was also found to have:
• Failed to put in place appropriate systems and controls at the firm;
• Failed to gather sufficient information about his customers’ personal and financial situations;
• Advised on mortgages when he was not qualified to do so; and
• Failed to make adequate changes after an external audit in 2008 found faults at UFIS.
It also came to light that Khan had two appointed representatives, of which one had no idea that he been registered as an AR at the time; the other never worked for Khan.
It was clear that Khan did not understand the regulatory requirements relating to registering ARs and he did not take any action to understand these rules.
