In CP146 the FSA proposes that training and competence in the form of formal examination is not required for non-advised mortgage sales other than lifetime mortgages. Commenting on this, Dr Sandy Scott, director general of CII said: “If the current recommendations are adopted we believe that in order to avoid the extra training and/or examination required firms could potentially offer a level of advice that does not meet the consumer’s needs. We believe this could lead to confusion for consumers with the potential for mis-selling.”
The CII is particularly concerned about consumers who would benefit from more advanced mortgage arrangements but may be advised on simpler products because the adviser is only qualified to do so.
The CII is calling for the FSA to:
• commit to formal training, competence and examination beyond the commitments;
• implement an ongoing competency system; and
• instigate specialist modules for higher risk mortgage advice such as equity release products.
Dr Scott said: “We believe that exams on their own can give too narrow a view of an individual’s competence. Likewise, maintaining a competence system without formal qualification is unlikely to give consumers sufficient confidence. We are therefore calling for an approach that has both core elements. We are also suggesting that ‘top up’ qualifications need not necessarily involve an exam but could be achieved through an assessment.”