apcc-liaison-meeting-10th-december

Report
FCA/APCC Liaison Meeting
10 December 2014
1
Agenda
2
11.30
Consumer credit (Nick Mears, Kim Heffernan & Sunil
Thakar)
1.00
Lunch & general discussion (Lucy McClements, Val
Smith, Gillian Lavabre, Andy Freeman & Emma Krygier)
1.30
MCD (as for lunch, plus Beverley Brewster)
2.00
Average determination times/AOB (Lucy McClements, Val
Smith, Gillian Lavabre, Andy Freeman & Emma Krygier)
2.30
Close
Consumer Credit
Nick Mears, Kim Heffernan & Sunil Thakar
3
Lunch & general discussion
Lucy McClements, Val Smith, Gillian
Lavabre, Andy Freeman & Emma Krygier
4
Mortgage Credit Directive &
Second charge lending authorisation
Beverley Brewster
5
Mortgage Credit Directive - General
information on authorisation process
•
We expect to be open to accept applications from second charge firms applying for mortgage
permissions in March/April 2015
•
Timing is tight:
• Directive comes into force on 21 March 2016
• Standard statutory timetable applies so we have six months to make a decision on complete applications and
12 months to make a decision on incomplete applications. Typically most lender applications are incomplete
• The more accurate and complete an application is, the quicker it can be assessed
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•
Firms should refer to the existing application form supplements for home finance brokers and
home finance providers/administrators for the information and policies and procedures that will
be required to be submitted with their application. Single set of mortgage permissions means
there will be a common assessment process for first and second charge firms
•
Firms should look at the consultation paper and MCOB and start thinking about the gaps in their
business now; this will help firms to fully complete their application
•
We will not authorise firms on a ‘just in case’ basis. Firms should only apply if they are actively
involved in the second charge market
•
Application fees for mortgage permissions are, in most cases, higher than those for consumer
credit. See the fees consultation paper published last month. Firms can use the fees calculator
on our website
•
Consumer Buy to Let is running on a different timeframe. Look out for HMT and FCA
consultations early next year.
Mortgage Credit Directive - What do
firms need to do?
Existing authorised firms with first charge mortgage
permissions
• Firms with first charge mortgage permissions and doing 2C
business in the same legal entity will not need to apply for
additional permissions as the existing mortgage definitions will be
extended to include second charge
• BUT, firms registered for consumer credit interim permission and
whose only consumer credit business relates to second charge
business should email [email protected] to request to
move their application period to March 2016 to avoid having to
make a consumer credit application. This way firms will keep
interim permission until the MCD comes into force.
7
Mortgage Credit Directive - What do
firms need to do (ctd)?
Consumer credit firms doing second charge and other
credit activities – application period ending March
2015 or earlier
8
•
Firms should apply during their agreed application period unless
they are contacted to move the date
•
If the consumer credit application is determined before we are
open to accept applications to add mortgage permissions firms will
need to apply to vary their permissions to add mortgage
permissions. There will be a fee to pay.
•
If the application is not determined, firms will be able to complete
a supplementary form and pay any top up fee due – we will
confirm the process early next year.
Mortgage Credit Directive - What do
firms need to do (ctd)?
Consumer credit firms doing second charge and other
credit activities – application period April 2015
onwards
9
•
Firms should consider applying before their agreed application
period for both credit and mortgage permissions – firms are
allowed to do this if they are adding non-credit permissions
•
An early application will increase the likelihood of application being
determined by March 2016
Mortgage Credit Directive - What do
firms need to do (ctd)?
Consumer credit firms only doing second charge
business
• Firms whose only consumer credit business relates to second
charge business will need to apply for mortgage permissions, not
credit permissions. Firms should complete the financial services
application form for home finance brokers or home finance
providers/administrators and not the consumer credit form. But
firms cannot apply until we are open to accept applications.
• Firms should email [email protected] to request to
move their application period to March 2016 to avoid having to
make a consumer credit application and to keep their interim
permission until the MCD comes into force on 21 March 2106.
10
FCA Information and Engagement
• We understand that firms want information and certainty.
We are continuing to work through the issues and we will
keep firms informed via the following channels:
•
Website - monitor for ongoing information
•
Regulation Round up and other FCA publications
•
Considering authorisation workshop or webinar specific to
authorisation process
•
Engagement with compliance consultants and trade bodies
• Remember, firms can also use the Contact Centre for
questions
11
Questions
12
Average determination times
& AOB
Lucy McClements, Val Smith, Gillian
Lavabre, Andy Freeman & Emma Krygier
13

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