United industry front vital to shape MMR

04 Mar 2011

With a distinct degree of continuity and cooperation that the protagonists have hardly been famous for in the past, the three main mortgage trade bodies – AMI, CML and IMLA – all issued their public responses to the latest MMR paper last week. 

While the Distribution and Disclosure Consultation Paper was the last document to spring forth from Canary Wharf, all three ‘trades’ were focused on MMR in its entirety, rather than one of its constituent parts.

As mentioned there was a fair degree of overlap and agreement in the three press releases and it will be no surprise to learn that all three have worked together in order to generate their individual responses. 

Without having seen the actual submissions to the FSA I would be very surprised to see them differ that much in substance; I would also suggest that the three taken together deliver the most focused ‘mortgage industry response’ to the regulator we have ever seen.

I have always been a great believer that our industry works better when it works together and it would seem that it has taken the MMR to bring about something akin to ‘peace in our time’. 

Certainly, the back-biting of the past particularly between AMI and the CML appears to have disappeared, which can only be a good thing given that the two sides need to work together to get the outcomes we all want to see.  Our market cannot and will not thrive if both lenders and brokers are singing from completely separate hymn sheets.

That is not to say that each trade body isn’t pushing for particular action in certain areas whilst at the same time setting out some scenarios they would like to see in place.  For instance, AMI’s call for compulsory advice will not be one shared by many of the CML’s members however one senses compromise in its suggestion this could be limited to ‘high risk’ groups such as the credit impaired, those borrowing into retirement or first-time buyers.  I do wonder how many lenders would view first-timers as high-risk but that is another point.

AMI’s compromise position is set out in its reaction to continued non-advised sales which it says it can live with if the position is clearly set out for consumers about the protections they will lose by following this route.  It would be remarkable if the non-advised/execution-only route was outlawed in some way, however, never say never, certainly when it comes to what edicts are coming from Europe in the near future. 

Clearly, all three trades are concerned about the MMR as it currently stands.  The issue being that clarity appears to be in short supply at present.  We have no real idea when MMR might be implemented, indeed, the only timetabled MMR event – the changes to the authorised persons rules bringing in the individual authorisation of mortgage advisers  - were not just put back by a few months but by a couple of years.  And one suspects this is hardly a set in stone date either.

So, as is rightly pointed out in these responses, the mortgage industry needs to feel slightly more assured and clued up on the FSA’s intentions for MMR.  I would also support bringing all the MMR proposals within one consultation rather than the situation we have now.  All issues and suggested proposals are inter-linked and cannot be decoupled from each other so it makes perfect sense to pull all facets of the MMR debate and eventual outcomes together. 

It would also help if, at this next stage, the regulator delivers its intended timetable for MMR implementation.  The trade bodies are right in that it is difficult to plan and prepare for something if you have no idea when it might begin; plus at this stage we are all second-guessing what rules will be introduced anyway.  The MMR proposals are already changing the market as lenders react to what they believe will be introduced which is a bizarre situation, to say the least.

And as mentioned previously, we have the potential fly in the MMR ointment of what European legislators are planning for the mortgage market.  With these proposals still unclear it would seem common sense to consult and incorporate what the EU is planning into the MMR now, rather than announce a raft of proposals first, only then to have to change and redevelop when the European measures are delivered.

All in all, the responses from the three trade bodies appear to present a unified call for the FSA to draw breath.  One would be hard pressed to disagree with this approach especially if the regulator is then able to provide a coherent strategy, based on industry responses, and a structured clarity about how they see the whole MMR process panning out. 

At present the industry appears to be in limbo and if we want to continue driving forward to deliver a far healthier mortgage market then it is appropriate for all to take their time and ensure we have the right proposals which do not damage the still fragile recovery we are witnessing.


Bob Hunt

Blog Archive

Opinion: The mortgage revolution is unfolding 
10 Dec 2018

Brokers’ fortitude will see them through this ‘depressing and dispiriting’ situation 
10 Dec 2018

Paradigm CEO Hunt invests in mortgage switching platform Dashly 
19 Nov 2018

We should be confident despite the uncertainties 
14 Nov 2018

FCA should leave mortgage market alone until Brexit uncertainty lifts 
09 Nov 2018

Not following EU rules could benefit the market 
16 Oct 2018

Long-term fixes fail to catch on 
01 Oct 2018

Mortgage market must ensure it deals in Project Clarity 
21 Sep 2018

Advisers can help landlords get their skates on for HMO changes 
11 Sep 2018

A deeper look at the state of the UK lending market 
17 Aug 2018

Understanding product transfers 
30 Jul 2018

‘Go compare’ is not so ‘simples’ 
26 Jul 2018

It’s worth looking into later life lending 
05 Jun 2018

SVRs are a cash cow for many mortgage lenders 
04 Jun 2018

Leaving a network should be more straightforward 
08 May 2018

Not all later life customers are in the same boat 
03 May 2018

Advisers must beware leasehold ‘minefield’ 
16 Apr 2018

It’s just not cricket 
12 Apr 2018

Proc fee timescales are way off 
29 Mar 2018

Broker-lender relations have undergone a fundamental shift 
28 Mar 2018

Opening at weekends shouldn’t be a priority 
13 Mar 2018

Take control to signpost clients in your direction 
22 Feb 2018

Product transfer: ‘Lenders might view greater adviser involvement as a problem’ 
12 Feb 2018

Buy-to-let advice is needed more than ever 
08 Feb 2018

Open Banking is a revolution without the fanfare 
16 Jan 2018

Land Registry needs to engage with brokers over Instant Mortgage 
08 Jan 2018

Simply focusing on age will not fix borrowing into retirement 
22 Dec 2015

Reduce the regulatory burden for firms by reallocating money from FCA fines 
03 Nov 2015

Customer choice has narrowed – the FCA could help fix this 
02 Nov 2015

The regulator’s differing interpretations of rules 
21 Oct 2015

Change is constant 
08 Oct 2015

Paradigm signs exclusive specialist lending deal with Brightstar 
06 Oct 2015

Landlords cash in on PRS 
22 Sep 2015

MCD – no grace but plenty of favours 
16 Sep 2015

Equity release success signals change in consumer perspective 
05 Aug 2015

Remortgagers play at ‘chicken or egg’ 
29 Jul 2015

BTL has closed the housing gap 
20 Jul 2015

Analysis: Writing a will can avoid a death blow 
15 Jul 2015

Industry deserves housing minister appointed to Cabinet 
22 Jun 2015

Waiving Stamp Duty won't encourage downsizing 
08 Jun 2015

Damned if they do, damned if they don’t 
01 Jun 2015

In the Spotlight with Bob Hunt 
26 May 2015

Election result provides stability 
20 May 2015

‘Grey borrower’ power is set to grow 
13 May 2015

Decisive election result could spur new build revolution 
27 Apr 2015

MMR 12 months on 
13 Apr 2015

Mind the protection gap 
09 Apr 2015

Analysis: Change status with the right support 
08 Apr 2015

Housing will be election battleground 
16 Mar 2015

Securing the specialist string to your bow 
04 Mar 2015

Interest rate direction is anyone’s guess 
04 Mar 2015

Regulatory B2L change is inevitable 
12 Feb 2015

Analysis: Do your homework with relationships 
04 Feb 2015

Lenders rising to the self-employed challenge 
04 Feb 2015

The sectors to watch in 2015 
06 Jan 2015

A helping hand 
05 Jan 2015

Can a landlord be truly ‘accidental’? 
17 Dec 2014

Coming in from the cold 
05 Dec 2014

Analysis: Why distribution demands inclusion 
12 Nov 2014

HSBC’s move signals cost of branch advice still rising 
20 Oct 2014

Analysis: Broker community boosted by HSBC 
15 Oct 2014

Just when I thought I was out 
08 Sep 2014

Analysis: Owning a home is not out of reach 
03 Sep 2014

Take level 4 advice exams before the FCA steps in 
02 Sep 2014

Analysis: Get set for more BoE intervention 
20 Aug 2014

Welcome to the Twilight Zone 
11 Aug 2014

Housing policy deserves seat at top table – Bob Hunt 
24 Jul 2014

MMR is enough to slow the bubble 
09 Jul 2014

Help to Buy remains in the spotlight 
08 Jul 2014

Mixed messages risk consumer confusion - Bob Hunt 
03 Jul 2014

It’s good to talk 
20 Jun 2014

H2B a rare housing policy success 
18 Jun 2014

Increasing mortgage volume will come through brokers - Bob Hunt 
27 May 2014

The better option to going direct 
14 May 2014

FCA concerned by packaging renaissance 
12 May 2014

Watch out for European regulation by year-end 
06 May 2014

Ask the Experts: Will MMR cause mass application declines? 
22 Apr 2014

Ask the Experts: Can a broker operate MMR-compliantly before 26 April? 
17 Apr 2014

Cross-sales not just for times of crisis 
16 Apr 2014

Brokers in the dock 
26 Mar 2014

Lenders in catch 22 situation over MMR - Bob Hunt 
25 Mar 2014

Paradigm launches protection arm 
21 Mar 2014

‘MMR Day’ may be a damp squib 
12 Mar 2014

Make sure your papers are in order 
12 Mar 2014

MMR lending slowdown could force protection bonanza 
18 Feb 2014

Countdown to MMR 
12 Feb 2014

A big year ahead for lenders 
04 Feb 2014

If the quality is same – why can’t AR & DA proc fees be equalised? 
30 Jan 2014

BoE is unlikely to be trigger-happy 
15 Jan 2014

We’re not in 2008 anymore 
09 Jan 2014

FCA cannot ignore views of smaller firms 
13 Dec 2013

The Prediction Game 
06 Dec 2013

Stay ahead of the regulator with CPD 
27 Nov 2013

Don’t let booming business hamper MMR preparation 
21 Nov 2013

Living up to expectations 
15 Nov 2013

MMR compliance underpins success 
30 Oct 2013

Advisers should step up to level 4 qualifications 
24 Oct 2013

Bank of England must follow words with actions 
02 Oct 2013

Lean times leave a leaner, keener core 
04 Sep 2013

If you don't ask lenders, you don't get 
22 Aug 2013

Steady as she goes is the right approach 
20 Aug 2013

Are we about to see a broker boom? 
16 Jul 2013

Now is not the time for procrastination 
10 Jul 2013

Improving standards is no grounds for complaint 
03 Jul 2013

Is product innovation being tied in knots? 
24 Jun 2013

We can’t rely on external stimulus 
06 Jun 2013

Put your services in the shop window 
06 Jun 2013

Mutual Magic 
30 May 2013

Does the FCA understand human frailty? 
07 May 2013

Has the mortgage market regained its mojo? 
17 Apr 2013

Help to Buy plus prudence equals prosperity 
05 Apr 2013

Will George Osborne be having a flutter ahead of the Budget? 
14 Mar 2013

Size matters on capital adequacy 
04 Mar 2013

Mortgage Indemnity Guarantees: helping first-time buyers fly 
19 Feb 2013

HS2? I’d rather see more houses built instead 
06 Feb 2013

95% LTV mortgages are not back... yet 
22 Jan 2013

Regulators have listened to feedback 
21 Jan 2013

The Great House Price Debate 
07 Jan 2013

Keeping your clients' wills up to date 
02 Jan 2013