Systems and enforcement

I called the FSA helpline and asked for assistance, and as I was speaking I happened to look in the ICOBS (new conduct of Business forms) section, and found the CIDD that I required.

I told the helpful lady that I had found what I wanted, but she said that there is another way to find a CIDD, and directed me to Doing Business with the FSA/Small firms/General Insurance Intermediaries/Disclosure, and there was a link to Combined initial disclosure document (CIDD) [DOC].

I thanked her and rang off, but when I examined this document, I was, to say the least, surprised to find this at the end of the notes:

[Lifetime] Mortgages [and home reversion schemes] [Note 14]

Mortgage advising and arranging is covered for 100% of the first £30,000 and 90% of the next £20,000 so the maximum compensation is £48,000. [Home reversion schemes are not covered by the Financial Services Compensation Scheme.] [Note 14]

Further information about compensation scheme arrangements is available from the FSCS.

[Note 40] Message from the Financial Services Authority

Think carefully about this information before deciding whether you want to go ahead.

If you are at all unsure about which lifetime mortgage or home reversion scheme is right for you, you should ask your adviser to make a recommendation.

Please remember that home reversion schemes are not regulated by the FSA.

So, our revered regulator had information that was 13 months out of date on its website, and brokers were still being directed to it. Despite the fact that I called the FSA back immediately to report this out of date document, it was still available on the FSA website weeks later.

Of course, the FSA will remind us that it is up to all of us to make sure that all our documentation is compliant with the rules in the Handbook, and any advice given by the helpline should be regarded only as 'guidance'.

But I shudder to think what the reaction of the FSA would be if they found that a broker had failed to update their documentation and that it was 13 months out of date.

Only recently the FSA publicly censured a mortgage broker for poor financial promotions, and Margaret Cole, director of enforcement at the FSA, said: "Poor financial promotions often go hand in hand with other problems at firms……………" Oh dear, I wonder what other horrors are waiting to be uncovered at Canary Wharf.

Get your act together FSA; brokers have worked very hard, often at great expense, to comply with the regulations, so it is discouraging to say the least to see that the regulator itself cannot keep its own website compliant

Robert Clayton

Swiftlearn Ltd

Bewdley

Worcestershire