It said that by giving lenders the responsibility to verify income and assess affordability, lenders might be expected to become more involved in the application process.
This could lead them to prefer direct sales over introduced sales, the FSA said.
The FSA also cited that in recent years there already appeared to be a trend towards the use of direct sales forces irrespective of the proposed rules.
However consultancy firm Oxera suggested that this trend may have been strengthened as a result of the proposed rules.
It said: “Lenders are likely to reduce the number of intermediaries they work with and rely more on their direct sales forces.
“This might disadvantage smaller lenders although they would still be in a position to use intermediaries to screen initial applications on their behalf if they find this beneficial as long as they retain ultimate responsibility to verify income and assess affordability.
“Each intermediary is still likely to have access to a sufficient number of mortgage lenders.
“Borrowers may face higher search costs to access intermediaries if the number of intermediaries is reduced.”
The FSA added that the reduction in the number of relationships between lenders and intermediaries would not significantly affect the degree of competition between lenders.
The analysis suggested that the proposals could, in principle, increase the role of intermediaries in the value chain.
It said: “Intermediaries would be able to help their customers in identifying lenders that would be willing to lend to them and help them prepare the relevant evidence required for income verification.
“However this is unlikely to be substantially different to what intermediaries are doing in the subdued market conditions we are experiencing at the moment where lenders are less willing to lend to some categories of borrowers.”
The FSA added that the requirement for some sellers to disclose cases in which they did not consider direct-only products for consumers may incentivise some consumers to move from intermediaries to direct-only sales.
It said: “This might have competition impacts through increased shopping around by consumers and increased price competition.”
