Paradigm is also offering firms an eight-point MCD ‘Action Plan’ on understanding their responsibilities and a flowchart for second charge mortgages called a Second Charge Mortgage factsheet.
Bob Hunt, chief executive of Paradigm Mortgage Services, said: “This week marks the start of MCD implementation as we know it with firms able to begin operating voluntarily under the new regime.
“Over the weeks to come we can therefore expect more announcements from lenders about how they intend to take this forward – communication which should be followed closely by intermediary firms.
“At the same time, it is absolutely imperative that advisory practices begin to put in place not just their thinking with regard to MCD compliance, but also a focus on the decisions that need to be made and the practical steps to be taken.”
He added: “Our second MCD update from Christine Newell offers further information which is important as we now have more detail on what is required.
“Add to this our Action Plan and Second Charge Mortgage factsheet and our aim is support firms thoroughly in this area.”
Paradigm’s update covers the following:
• Use of the word independent or unlimited product range.
• Buy-to-let and the introduction of regulated consumer buy-to-let.
• Disclosure rules if the client is borrowing more.
• Provision of a list of lenders and their procuration fees.
• Binding offers.
• The introduction of a reflection period.
• The replacement of the KFI with ESIS or KFI-plus.
• Issuing the ESIS or KFI-plus.
• Simplified financial promotions.
• Foreign currency mortgages.
• Tying or bundling of products.
• Removal of transitional arrangements.
• Disclosure of third-party commission.
