The code sets down a range of standards - from compliance to training and succession management - that RAMP’s packager members must work to. It was agreed by all 10 members of the organisation this week following several months of discussion.
The key elements of the code comprise:
Senior management controls and organisation. Members will ensure that they have the resources to be able to effectively manage and control their business. Managers should be appointed functions as set out in the FSA Supervision Handbook (CF1 to CF27).
Compliance members should have a designated department or individual tasked with the responsibility for ensuring compliance with the RAMP code. Controls will be put in place to ensure that FSA regulated activities are not undertaken unless the member has in place the appropriate FSA part IV permission. Telephone call recording equipment will be in place to ensure compliance with FSA rules.
Training. A robust training and competence regime and regular assessment of employees should be in place at all RAMP members. During their induction employees must be fully supervised and trained as necessary.
Succession planning and disaster recovery. Members should have arrangements in place that ensure their business can continue to function in the event of any unforeseen incident. Disaster recovery arrangements will be regularly updated and tested.
Complaints handling. Members will have in place a complaints handling policy to ensure that all customer complaints are handled in accordance with the FSA’s requirements. Complaints must be handled fairly, effectively and promptly. A record must be kept of all complaints.
Data protection and consumer credit. Members must have in place a valid data protection notification and, where relevant, a Consumer Credit License. Procedures to protect all personal data should be implemented that ensure compliance with the Data Protection Act 1998.
John Rice, Managing Director of the Regulatory Alliance of Mortgage Packagers (RAMP), said: “FSA regulation is raising the game in the mortgage market and only those packagers that embrace it and work to the highest possible standards will thrive. RAMP is in the vanguard of setting the pace in the packaging community and this code of conduct gives intermediaries a peace of mind when dealing with RAMP members that they may not be able to get from other packagers. It is intended to protect honesty, integrity and reputation and to demonstrate competence and capability.”
Mr Rice added: “Complete elimination of risk is not attainable, but this code of conduct, allied to effective compliance monitoring, will reduce and control risk.”
