AMI and its sister trade body, the AFB, has long supported the move of second charge loans to FCA regulation and the move to a unitary regime for all such loans makes sense. However it has said it will be responding with some vigour on other matters in the consultation
Robert Sinclair, chief executive of AMI, said: “In dividing the buy-to-let market by applying some artificial distinctions we are concerned that some elements may be marginalised and therefore ignored by lenders.
“This will not be a good outcome for consumers. In addition we are concerned that whilst most buy-to-let lending will sit outside the regulatory regime brokers, will be fully captured under the consumer credit provisions, which remain opaque.
“The consultation also delivers new legislation for the registration of appointed representatives which might have sense in isolation, but unless all advisers from all channels are captured will do little to address the risks set out in the near final rules surrounding CF31 which the FCA has still to implement. We await the FCA consultation on this with some interest.”