SRT and Basel 3.1 – are you ready?
We are often asked by our clients to comment on market trends and movements. Significant Risk Transfer [‘SRT’] is currently dominating our conversations, and much of our work, especially our AUP services connected with SRT issuance programmes. 12 September 2024 is a key date that will lead to a seismic market shift – are you […]
Niche lenders, back in the driving seat?
The UK lending market is in the grip of a seismic shift, driven by significant M&A activity, choices being made by laggards in the digital transformation race and the regulatory impact of tightening capital requirements. Just like in any market change, adjustments also present opportunities. The changes taking place will be exploited by nimble niche […]
Mortgage Charter Independent Oversight
The FCA has released its first report analysing the impact of the Mortgage Charter. Launched exactly a year ago, the Charter received some negative industry comment, with a number of lenders suggesting that they already had robust forbearance measures in place and it wasn’t needed. However, on any measure, the FCA data shows positive consumer […]
FCA complaints – a worsening picture
Increasing numbers of complaints, and the lack of real resolution by firms, is not new news, but regulators are becoming impatient for change. After years of TCF and more recently Consumer Duty implementation, it is not surprising that they are questioning when they will see improved outcomes. So why are regulators becoming increasingly tired with […]
Another FCA warning shot
The most recent FCA ‘strategy letter’ on consumer lending is one of the most detailed we have seen, and it focuses on three portfolios; high-cost lending, mainstream consumer credit lending and credit unions. This is an unusual step for the regulator, as it normally issues separate letters to each portfolio. However, on this occasion there […]
Regulators warnings on debt collection
A quartet of regulators, FCA, Ofgem, Ofwat and Ofcom have recently reaffirmed their joint commitment to increasing standards in debt collection activities. Their update comes as part of Debt Awareness Week 2024 and follows on from a letter they jointly published in June 2023, which set out their shared expectations as to how firms from […]
UK RMBS is alive and well
We have noticed recent trade press commentary stating “UK RMBS is back”. Clearly positive news, but in our view, it has never been ‘away’. To be clear, when commenting on UK RMBS we need to distinguish between, and consider the position of, ‘non-bank’ and ‘bank’ providers. Certainly, the involvement of non-bank lenders has been consistent […]
GAP insurers now under the spotlight
The motor finance world is feeling the regulatory heat right now. As previously reported and commented on, PCP plans have been heavily scrutinised, with hidden commissions being at the top of the ‘must do better’ list. While the FCA review remains in progress, we now see that 80% of Guaranteed Asset Protection firms have agreed […]
Lenders unwind affordability stress tests
Back in the summer, when the BoE confirmed that it would withdraw its affordability test from August 2022, we wrote a blog questioning the timing. To recap, the requirement was introduced in 2014 with the intention of preventing loosening of credit assessments and to ensure that reckless lending would not cause an economic downturn putting […]
Service Level Agreement ‘SLA’ oversight
Regulators, including the BoE, PRA and FCA, are renewing their attention on how firms manage and control the third parties that they work with. Most regulated firms are used to working within the SYSC rules to manage third parties, but the new focus considers additional oversight in respect of critical third parties. One area of […]
