2018年-FCA英国金融行为监管局_ms16_2_2_annex_7_10页_334kb

Summary of Annex 7: Additional findings on commercial relationships

Core Content

Annex 7 of the MS16/2.2 Market Study provides additional insights into the commercial relationships between lenders, mortgage intermediaries, and other market participants such as estate agents and price comparison websites (PCWs). It examines how these relationships affect consumer choice, market dynamics, and the pricing of mortgage products.

Main Findings

Intermediaries' Panel Management

• Intermediaries use varied strategies for managing and reviewing their lender panels.
  • Some maintain limited panels, while others include a wide range of lenders.
  • Panels are often reviewed frequently or on an ad-hoc basis.
• The goal is to provide a broad range of solutions to meet diverse consumer needs.
• Larger intermediaries may focus on specific segments, such as underserved borrowers.
• Factors influencing panel selection include:
  • Lenders' service and proposition
  • Brand reputation
  • Product types offered
  • Support provided to intermediaries
• In 2016, 43 intermediary firms added at least one lender to their panel:
  • 79% added 1–5 lenders
  • 16% added 6–10 lenders
  • 5% added more than 11 lenders
• Some lenders faced rejection due to similar propositions already on panels.
• A few intermediaries have closed panels that may restrict access and create barriers for smaller lenders.

Relationships with Estate Agents

• Around 32% of intermediaries had arrangements to receive referrals from estate agents.
• These intermediaries had a combined market share of about 20%.
• Most intermediaries do not rely heavily on referrals from estate agents.
• Some estate agents have internal referral processes and may provide disclosure leaflets to consumers.
• There are concerns that some estate agents may pressure consumers to use their in-house mortgage advisers.
• Consumers may feel pressured to consult an adviser to secure a property sale.
• Referral remuneration typically involves a percentage of the procurement fee (25–35%).
• No evidence of volume-based or exclusivity-based fee increases was found.

Mortgage Pricing and Intermediaries

• Mortgages arranged through intermediaries with estate agent ties are not significantly more expensive than those through other intermediaries.
• Intermediaries generally do not charge fees for new build mortgages, which may be a requirement to be on a developer’s panel.
• The mortgage intermediary market in the new build sector is more concentrated than the overall market.
• Developers often have relationships with intermediaries but do not typically charge fees or offer incentives for referrals.

Relationships with Price Comparison Websites (PCWs)

• PCWs are widely used by consumers during mortgage shopping.
• Most lenders list their products on PCWs, though not all have formal agreements.
• Commercial arrangements with PCWs are usually initiated by lenders and are based on metrics like traffic and referrals.
• Most PCWs do not charge lenders for simply appearing on their site; instead, they use CPA or CPC models.
• Only a small number of intermediaries have relationships with PCWs, and these are often historic.
• PCWs do not significantly affect product pricing or consumer choice, though some show sponsored products due to commercial relationships.

Key Information

• Panel Strategies: Vary by intermediary, with a focus on consumer needs and market segments.
• Estate Agent Influence: Some estate agents recommend specific intermediaries, which can impact consumer behavior.
• Referral Fees: Typically a percentage of the procurement fee, with no evidence of exclusivity or volume-based fees.
• New Build Market: More concentrated, with intermediaries often working closely with developers.
• MSS Relationships: Lenders and intermediaries use mortgage sourcing systems (MSSs), which do not appear to restrict product visibility or innovation.
• Ancillary Services: Some intermediaries offer valuation and conveyancing services, which may lead to conflicts of interest.
• MFNs (Most-Favoured Nation Clauses): Narrow MFNs exist but do not significantly restrict competition; wide MFNs are not found in the mortgage sector.

Conclusion

The commercial relationships between lenders, intermediaries, and third-party entities such as estate agents and PCWs are complex and varied. While some relationships may create barriers or influence consumer behavior, the study found no significant evidence of unfair practices or substantial price differences. The role of intermediaries in facilitating access to mortgage products remains important, and the market continues to evolve with new technologies and business models.