Commenting on the options, SPML’s director of credit, Stuart Aitken, said: "Work under supervision. Within firms, individuals who have already passed the full exams can supervise those who are not yet qualified. Supervisors need to be ‘suitably competent’ and the advisers would have to be classified as ‘trainees’. They would then have a maximum of another two years to pass their remaining exams. A list of supervisors and the advisers they are responsible for needs to be maintained.
“Change to ‘Information only’ status. Advisers only need to have passed the exams to provide the service level of ‘Advice and a recommendation’ under the Mortgage Code. Information can still be offered without passing the exams, but intermediaries must be able to demonstrate that only information has been provided and that it has been made clear to the customer that no advice has been given. Firms must notify MCCB of this change of status within 21 days, and may receive a visit from MCCB if this option is taken.
“Downgrade to ‘introducer’ status. Not a realistic option for most. ‘Introducers’ would need to send their cases through another MCCB registered firm or network, but could still receive some/most of the procuration fee. This is a possible option for smaller firms; those looking to move away from regulated business completely; or as a temporary ‘fix’ until the exams are passed. Introducers need to be very careful not to do any more than just ‘introduce’ the customer to the MCCB registered firm.
“Do nothing! This is not an option that SPML would recommend! The risk to current business under the Mortgage Code and MCCB rules is a big one. There is also the risk of affecting a firm’s ‘good standing’ with MCCB, something that will be very important when applying to the FSA for mortgage authorisation."
