"We welcome the major points that show the FSA has listened to feedback. For example, the scrapping of client money rules for intermediaries more truly reflects actual practice. We are pleased that self certification for the employed is to be allowed, as it is a normal and well established part of mortgage lending. The new KFI APR accuracy limits offer a greater degree of tolerance and will allow brokers to continue to use sourcing systems. In particular, the question of packager remuneration has been clarified. SPML has long been arguing for packager administration fees to be separated from procuration fees, and this has now been fully recognised in the mortgage rules which now do not require disclosure of packager administration payments.
“We are pleased that the FSA is clearly trying to make life simpler for intermediaries. For example, the emphasis on the high level principles gives a rigourous framework for intermediaries to act in a reasonable way, without specifying finer details. The document itself is also a reasonable length - if the large section on lifetime mortgages, and other sections for lenders are discounted, there are really only about 100 pages for intermediaries to concentrate on."
