Broker Toolbox: Understanding and adopting disclosure requirements

by: Steve Walker
  • 23/06/2015
  • 0
Broker Toolbox: Understanding and adopting disclosure requirements
As all mortgage brokers will be well aware, when it comes to arranging a mortgage or loan, part of the cost involved is getting hold of the client in the first place.

As the saying goes, time is money, and often it can take three or four phone calls just to finally get a chance to speak with the client.

Indeed, in an increasingly technological world in which most of us have a mobile phone, it is still frustratingly difficult to contact clients at times.
Well, if you think it’s bad now my friends, it seems it’s about to get worse.

With March 2016 fast approaching, we’re starting to hear more information from the Financial Conduct Authority about what the Mortgage Credit Directive will entail. One piece of information that has become prominent in the last few weeks surrounds disclosure.

Speaking at the Financial Services Expo in Manchester, FCA mortgage technical specialist Keith Hale suggested that one of the major changes for advisory firms could be around the disclosure of their service scope and the remuneration they receive, suggesting there could be “challenges” for firms particularly around service disclosure which now has to be in a ‘durable medium’.

Here is the sticking point. This service disclosure cannot be provided over the phone, causing major problems for those firms that initially speak to their clients via telephone conversation. The disclosure documents would, instead, have to be provided by email with the firm allowing the client enough time to read and understand the document before continuing with the sales process.

Brokers will have have to email the documents to clients and then arrange further time to call the client back once they’re satisfied they have opened and read the document.

This, of course, makes the process slow and cumbersome. It takes much longer for the client to get the result they want and it takes up more of the broker’s valuable time.

Furthermore, it leads to a certain ambiguity as to when the advice process actually begins. Is it during the opening conversation (i.e. pre-application) or application onwards (pre-fact find)?

Thankfully technology may provide you with some help; for example sending your Initial Disclosure Document (IDD) as an attachment to your “thank you” email when someone applies on your website. When you load enquiries in to your CRM system can it generate an introductory email to potential clients telling them you will be calling and can you attach your IDD?

If you prefer to warm your clients up with a phone call first then you may be stuck with a cumbersome two call process, but given you are very unlikely to be cold calling the two approaches above should help to deal with most scenarios.

Bolting on a disclosure document to a pre-sale email process many firms have had in place for years seems pretty easy. If you don’t currently introduce yourself to clients by email maybe now is the time to look at a process to do so and adding the IDD will be simple in 2016.

Steve Walker is MD of Promise Solutions

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