2017年-FCA英国金融行为监管局_tr16_4_embedding_the_mortgage_market_review_4页_195kb

报告摘要

Regulator Assessment Summary: Embedding the Mortgage Market Review: Responsible Lending Review (TR16/4)

Core Content

This document outlines the findings of the FCA's thematic review on the implementation of responsible lending rules under the Mortgage Market Review (MMR). The review was initiated in April 2015 and published in May 2016. It evaluates how mortgage lenders across the UK have embedded the MMR requirements, which were developed in line with the anticipated form of the Mortgage Credit Directive (MCD), even though they were not directly derived from EU legislation.

The review focuses on the effectiveness of responsible lending rules in ensuring that mortgage lending is fair, transparent, and suitable for consumers. It includes an assessment of affordability, treatment of existing and interest-only borrowers, and the use of exceptions in lending decisions.

Main Findings

Firms have generally engaged positively with the responsible lending rules.
No evidence of previous poor practices such as self-certification of income or interest-only lending without a credible repayment strategy was found.
Affordability assessments are largely effective, though there are opportunities for improvement in monitoring and record-keeping.
Lending to specific groups such as older borrowers and the self-employed does not appear to be negatively impacted by the rules.
Potential issues related to older borrowers will be addressed in future strategy work on the ageing population.

Impact on Businesses

Affected Businesses

Type of business: All authorised mortgage lenders.
Estimated number of firms: 250.

Cost Estimates

Familiarisation costs: £18,000 for all 250 firms to read the report.
Gap analysis costs: £744,000 for the sector, based on an estimated 62 hours of work per firm at £48/hour.

Gap Analysis Breakdown

QRP	Description	Estimated Hours
1	Improvements to affordability assessment process monitoring and record keeping	0
2	Improve decision making	2
3	Being more proactive and consistent using exceptions	4.5
4	Recording keeping needs to improve	2
6	Improving accuracy of online calculators	10
9	Some firms struggled to assess income in line with their policy	4
10	Bad practice of only using one payslip to estimate income	2.5
11	Continue to ensure realistic assumptions used with expenditure data	5.5
12	Ensure rationale for rate used in stress tests is credible	2
13	Lenders must consider likely future interest rates	1
15	Firms need to be able to demonstrate how lending decisions were made	3
16	Management information not always accurate, sometimes key details missing	5
19	Retention strategies and easy switching for consumers	0.5
20	Improving process for customer experience (e.g. shortening appeals)	2
21	Firms reviewing themselves against Annex 2	12.5
22	Consider fair treatment when customers want to change their mortgage	5.5
Total	Average hours across industry	62
Total cost	£48/hour x 62 hours x 250 firms	£744,000.00

Likely Benefits to Firms

Clarity and efficiency: Improved clarity may allow firms to streamline processes, reducing duplication and repetition.
Customer experience: Better processes could lead to a more positive customer experience, resulting in fewer complaints and better retention.
Resource allocation: Enhanced processes may free up resources to assist more customers, potentially leading to cost savings or increased business.
Compliance improvement: Firms that have not yet met the standards can improve their compliance, avoiding regulatory action or reputational damage.

Additional Information

The review does not introduce new obligations for firms, as the rules were already in place.
The cost estimates are based on the assumption that experienced compliance staff will implement the changes at a rate of £48/hour.
The FCA has not quantified the potential benefits of the review, as it is considered impracticable to do so.
The thematic report TR16/4 and discussion paper DP16/1 are available for further reference.

Conclusion

The review highlights that while mortgage lenders have largely implemented responsible lending rules effectively, there are still areas for improvement. The FCA has provided a detailed assessment of compliance gaps and estimated the associated costs, which are expected to be borne by the sector. The benefits of the review, though not quantified, are anticipated to include enhanced process efficiencies, better customer outcomes, and improved compliance.

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