According to IMLA, mortgage lenders have embraced the Financial Services Association’s (FSA) TCF directive, but brokers have some way to go.
- Lenders have implemented wide ranging TCF programmes variously under the responsibility of managing directors/CEOs (43 per cent), TCF managers, compliance directors, or risk departments (each 7 per cent)
- 50 per cent of respondents report that changes to product design or product lifecycle processes have been undertaken
- However, many lenders feel that brokers have not fully understood or embraced TCF
- Support from the lending community and FSA can help enhance intermediaries’ knowledge of, and preparedness for, TCF
In response to FSA directives regarding TCF, lenders have spent considerable time and money setting up systems and processes to achieve compliance, and this investment is already showing results, according to IMLA’s latest survey of members.
The FSA requires all regulated firms to treat customers fairly and with integrity, and provide clear, useful information about products and services so that customers can make fully informed decisions.
Guy Batchelor, chairman of IMLA, said: “Lenders are taking TCF very seriously. For 43 per cent of them responsibility for implementation and compliance rests at managing director or CEO level, while for others it falls to the compliance manager or risk department, or they have appointed a specific TCF director. Many have TCF working groups and use a variety of mechanisms to deliver TCF.”
On the other hand, the survey did unearth some concerns in the lending industry that many brokers have not grasped the FSA directive with the same vigour.
Guy Batchelor continued: “There was a feeling that TCF must be embedded into the entire supply chain to include all third party providers. Over 80 per cent of our members expressed some concerns that brokers are less than fully prepared for TCF. Given the pivotal role brokers play in interacting with customers, it is clearly important that they play a full role in delivering TCF.
“Lenders can assist intermediaries in getting up to speed, and we also believe there is scope for the FSA to play a greater role in communicating TCF to the intermediary community."
