Since I joined Enterprise Finance at the beginning of 2014, there have been a number of notable milestones from a compliance point of view, both internally and externally. The first item to prepare was on the dissolution of the Office of Fair Trading and the subsequent transfer of regulation of second charge mortgages to the Financial Conduct Authority (FCA). This represented the initial step on the road towards bringing secured loans from the consumer credit regime into the main home loan rules and the European Mortgage Credit Directive (MCD), a journey that will take us through to implementation in March and the new regime beyond that.
Other early compliance projects last year included our acquisition of West One Loans and the subsequent integration of compliance processes that followed.
But it has been the MCD project that has dominated much of our thoughts in the compliance department and we are keen to ensure everything is implemented well in advance of the March 2016 deadline. We took our initial plan to the board at the beginning of 2015, before spending three months preparing and finessing what our final submission to the regulator might look like. Having submitted our application to vary our permissions to the FCA in mid-June, we received confirmation that we had been successful just 11 weeks later at the end of August.
Between now and March, much of our focus will be on getting advisers ready for the new regime through training, testing and roleplaying. As much as you can prepare for the new regime and understand the objectives of the new legislation, it’s only when you walk through the different eventualities that the various issues that may arise come to light, so it’s important that intermediaries consider this in advance.
In compliance the job is never completely finished as there are always new legislative changes to be aware of and cases to learn from. Intermediaries can be rest assured that even once next March’s MCD implementation date has been and gone, we will still be on hand to educate and advise on compliance matters so we can help them support their clients.