Focusing on Financial Promotions within the non-conforming mortgage sector, the factsheet has been designed to help brokers address common errors within non-conforming Financial Promotions.
Covering the areas of APR requirements, risk warnings, record-keeping and fee information, it also highlights the importance of the Financial Promotions approval process.
The factsheet follows a Financial Services Authority (FSA) review into non-conforming Financial Promotions, which revealed a lack of understanding of the Financial Promotions guidance within the sector.
Rob Griffiths, associate director at AMI, said: “The FSA’s progress update stressed the need for improvement from mortgage intermediary firms in the standard of their Financial Promotions, particularly in the non-conforming sector. It singled out non-conforming Financial Promotions as potentially targeting more vulnerable customers and therefore felt it needed to focus specifically in this area, especially on those promotions produced by smaller broker firms.
He added: “The regulator has issued a warning that it will not just focus on repeat offenders but those firms who have failed to grasp, or show awareness, of the rules.
“The FSA has historically adopted an educational stance in this area but the threat of enforcement action is there for those firms who continue to flout the rules.”
Alan Lakey, senior partner at Highclere Financial Services, admitted Financial Promotions rulings were confusing. He said: “It is definitely the case that people are worried about what to put in Financial Promotions. The FSA needs to lighten up a little. If it is moving to a principles-based approach why are there still rules?
“If, as a result of unclear Financial Promotions, consumers are put at detriment, then it needs to be addressed. But if it is small things that have no affect on the consumer then the FSA should step back.”
He added: “People shouldn’t be quoting rules, but quoting common sense.”
