While the new rules will allow some sales to remain execution-only where staff will not have to be qualified to CeMap Level 3, many lenders will be facing a choice about whether to train them anyway.
Claire Richardson, vice president of workforce optimisation solutions at Verint, said with stricter rules in place banks will be under pressure to prove they have done their due diligence.
She said: “When dealing with mortgage requests they will need to prove they have asked all the right questions, carried out adequate background checks and documented all this information accurately.
“Phone calls of this nature are already recorded for compliance purposes, but where questions start to arise is how banks ensure compliance is met during face-to-face meetings with mortgage advisers in branch.”
The new rules mean advice must be given to customers increasing their level of borrowing and while some discussions where product information only is given can be execution-only, as soon as product suitability is mentioned advice will be compulsory.
Richardson added: “Part of the problem lies in gaining a holistic view of the entire mortgage process – everything from discussions with call centre staff or advisers in-branch to the role of the back office in distributing paper work, completing background checks, completing final agreements and so on. Every layer of this process has the potential for error and gaps in compliance.
“What’s needed is a method, with the right technology as the backbone, to check and record each stage of the process more accurately as it moves from different departments.”
The FSA said it is planning “a firm engagement programme” for the implementation period.
It hopes “to help firms understand the MMR reforms, encourage firms to carefully address any systems changes that may be needed as a result of them and to keep firms informed of the next steps in our implementation strategy”.
The regulator confirmed it intends to conduct a formal review of the impact of the rules not more than five years after implementation.
