The buy-to-let and self-certification specialist lender said although it does not operate any branded lending arrangements it is clear those firms who are involved in this area need to ensure they hold the necessary FSA permissions to carry out any regulated activities associated with this type of operation.
Post-’Mortgage Day’ TMB will also deal with brokers who are not regulated because it specialise in arranging non-regulated buy-to-let mortgages for its clients.
TMB is in the process of asking the packagers it deals with to sign new Terms of Business which cover the basis of the relationship in detail.
Bill Dudgeon, managing director of TMB, said: “The Terms of Business basically outlines what we expect from our packagers and also what we can provide them. Our stance is that packagers provide outsourcing of the administration which we believe, at this stage, is not a regulated activity. So the terms are just a way of laying down our general expectations.”
Vic Jannels, managing director of All Types of Mortgages (AToM), said: “For those packagers that have taken the time and effort to become regulated it is unreasonable, although possibly acceptable, that some lenders will use non-regulated packagers. As long as this relates to unregulated business only then it is difficult to argue the case.”
“However, I will be interested to see how the FSA deals with complaints where unregulated packagers have been involved and where mistakes occurred,” Jannels added.
