Following their first publications of Temporary Guidance for firms between March and July 2020, the FCA followed up with their additional expectation of firms for mortgage, overdraft and consumer credit products in September.
The Additional Guidance follows up on several themes from earlier releases, including what to do once payment deferral periods come to an end, but the notable new material includes granular expectations around areas such as policy, quality assurance (QA) and vulnerable customers.
Coverage areas include:
- Credit Rating Agency Reporting
- Delivering effective forbearance
- Reviewing customer arrangements
- Customer engagement and communication
- Refinancing and creating sustainable arrangements
- Income and expenditure assessments
- Supporting vulnerable customers
- End to end quality assurance
- Training, competence, and incentives
- Governance and oversight
- Debt help and guidance
FourthLine’s free downloadable toolkit includes the relevant guidance from the FCA’s papers for mortgages, consumer credit and overdrafts, along with our own key considerations for each point. We believe firms should be asking themselves these self-assessment questions as they implement new measures or validate existing compliance.
Download our new toolkit featuring September’s Additional Guidance Self-Assessment Toolkit here>
Download our Temporary Guidance Self-Assessment toolkit here>
For any queries relating to the toolkits or support in implementing or validating either the temporary or additional guidance, please schedule a free 30 minute consultation with Ross Molyneux here>
Note: The information contained within the Toolkits are of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.