Mortgage Market Review: Approved Persons Regime

APPROVED PERSONS REGIME

The UK mortgage industry is in much debate around the various policies being communicated by the FSA under the Mortgage Market Review (MMR). Whilst the current focus appears to be on responsible lending and the affordability assessments, little seems to be said of the new Approved Persons Regime.

In June the FSA published PS10/9 MMR: Arrears and Approved persons. In the Policy Statement (PS) the FSA stated "We intend to proceed with all our approved persons proposals having further refined the scope of who is caught." With near final rules published in the PS, it was anticipated that the final rules and a “definitive implementation date” would be published in September. At the time of writing, this does not appear to have materialised.

Mortgage firms should not be complacent but continue to prepare for implementation. With the proposed new CF31 (Home Finance) controlled function and intention for mortgage firms to have compliance oversight responsibilities, firms should ensure readiness, pending issuance of final rules.