Guess who offered these words of wisdom: “I know what is around the corner – I just don’t know where the corner is. But the onus is on us to perform and we must control the bandwagon.” Do you know who it is yet? None other than prodigal son Kevin Keegan, who announced his return to Newcastle football club, of course.

Cue tenuous link. These words came to mind when assessing the FSA’s comments over the past months on the Retail Distribution Review (RDR). The FSA has continuously denied the mortgage market will come under the RDR, in line with other areas of the financial services market, particularly those governed by COB rules.

However, back in November, Stephen Bland, then director of the FSA’s small firms division, said it remained “open-minded” as to whether the RDR could benefit the mortgage sector. He also said: “I see this as being in the hands of you, the industry, so that market failures are addressed by industry solutions in the first instance and regulatory intervention is reserved for those failures that cannot be addressed, or have not been addressed by the market itself when it had sufficient opportunity to do so.” I see. We don’t know what is round the corner, but there may be something and we have to be prepared for it. At least, that is what I think he meant.

Thank goodness then for the Intermediary Mortgage Lenders Association, which released its views on the RDR last week, if a little later than the rest of the market. It has accused the regulator’s proposals of “bordering on the irresponsible in their potential impact on the mortgage industry”.

I am glad that someone has at last elected to speak plainly. The association then went on to say the potential for regulatory creep is huge and the current RDR debate is creating an environment of uncertainty about the future shape and structure of the mortgage market. Ultimately, what is round the corner for the mortgage industry is as clear as Keegan’s quote!

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The problem is if – and some believe when – the FSA finally realises a regulated financial services market with tiers of advisers from which the mortgage sector is excluded is unworkable, it may steamroll in new changes that could destroy MCOB as we know it.

The concern over RDR should not mask a more imminent change to hit the market – the March deadline for treating customers fairly (TCF). According to exclusive research for Mortgage Solutions conducted by West Brom for Intermediaries, over 80% of brokers are ready and prepared. Only 5% of the 920 intermediaries questioned said they still had a significant amount of work to do.

This is certainly satisfying to hear, and we hope 100% of all mortgage brokers can demonstrate to the regulator that they have embedded TCF into their business models. The regulator, if unclear about some things, has been perfectly unam­biguous about the March deadline, and there are no excuses to be non-compliant in this area. n