2017年-FCA英国金融行为监管局_financially_vulnerable_customers_thematic_review_new_logo_7页_227kb

Regulator Assessment Summary: Financially Vulnerable Customers Thematic Review

Core Content

The FCA conducted a thematic review on the impact of mortgage interest rate increases on financially vulnerable customers, starting in January 2016 and publishing findings in September 2016. This review is not linked to any EU directives or rules and is part of the FCA's ongoing efforts to ensure fair treatment of customers under changing economic conditions.

The review followed the previous thematic report TR14/3 (2013/2014), which encouraged firms to identify customers likely to be affected by rate rises and to develop proactive strategies to engage them. The current assessment restated these recommendations and provided examples of how some firms were preparing for potential interest rate increases.

Key Areas of Focus

• Identifying financially vulnerable customers: Firms are expected to use credit reference agency (CRA) data and other indicators to detect customers at risk of financial stress.
• Mitigation strategies: Firms should develop strategies to treat vulnerable customers fairly, such as removing barriers to product transfers, providing staff training, and developing online mortgage calculators.
• Lenders' communications: Proactive communication with customers and collaboration with debt advice agencies were emphasized.
• Monitoring the impact: Firms should regularly assess the impact of interest rate increases on their mortgage portfolios.
• Preparing for an interest rate rise: Firms are encouraged to take action now to be better prepared for future rate increases.

Main Findings

• Scope: The review applies to all mortgage lenders and third-party administrators across the UK, targeting approximately 130 firms.
• Compliance Status: The majority of firms had already developed strategies to mitigate the impact of rate rises, though they were at different stages.
• Familiarisation Cost: Estimated at £1,040 for the sector, based on one staff member per firm reading the document for 10 minutes at an hourly rate of £48.
• Cost Estimates:
  • Mitigation strategies: One-off cost estimate of £171,000 for the industry (midpoint of £114,000 to £228,000).
  • Monitoring the impact: Ongoing annual cost estimate of £120,000 for the industry (midpoint of £80,000 to £160,000).
• Benefits: Firms may reduce the risk of customers entering arrears and better prepare for resource implications.

Cost Breakdown

Estimated Impact

• Total one-off cost: £171,000 (for mitigation strategies).
• Total ongoing cost: £120,000 per year (for monitoring the impact).
• Sector-wide impact: The review is expected to affect approximately 70-75 firms in the mortgage sector.

Additional Notes

• The review does not introduce new regulatory requirements but reinforces the recommendations from TR14/3.
• Some firms may benefit from using existing tools or strategies, reducing the need for new development.
• The FCA encourages firms to collaborate with debt advice agencies and to use proactive communication methods to support financially vulnerable customers.