AMI Dinner 2022: the night in pictures

AMI Dinner 2022: the night in pictures

TSB sponsored this year’s event which opened with a speech from the association’s chair Andrew Montlake, then a speech from the trade body’s chief executive Robert Sinclair.

Environmentalism was the theme of the evening as AMI pledged to plant a tree for every guest in attendance. Attendees were also addressed by speaker Roger Harrabin, environment analyst at the BBC, who discussed climate change and how the mortgage sector could play its part in mitigating it.


BSLS2022: Consumer duty ‘much more significant’ for specialist lending sector

BSLS2022: Consumer duty ‘much more significant’ for specialist lending sector

Speaking at the British Specialist Lending Senate, Robert Sinclair, chairman of the Association of Mortgage Intermediaries said that upcoming consumer duty was a “fundamental sea change from treating customers fairly”.

The Financial Conduct Authority (FCA) launched a consultation into a new consumer duty at the end of last year, saying at the time that it had seen multiple examples of firms presenting information that exploited the behavioural biases of their customers, sold products or services that were not appropriate, or poor customer support.

He explained that it was about “being able to evidence that the customer got what they expected”.

“How do you evidence that you’ve had that dialogue with the customer to prove that? That they are getting the right product for their needs is what sits at the heart of this and delivering that expectation is a very, very difficult contract to meet,” Sinclair added.

He noted that if companies had to prove when they market and design a product that the receiving customers “actually got the right thing”, it could be “really complicated”.

Sinclair continued that this change could be “much more significant” for the specialist lending market as it potentially had a higher cohort of people who could potentially be deemed as vulnerable.

He said evidencing and measuring vulnerability would be very challenging, adding that the vulnerability assessment will have to become “more tangible”.

Sinclair said key four outcomes of consumer duty were effective communication, assessing products and services, price and value.

He said the crucial element for him was around defining service proposition, stating that the way consumer duty is currently drafted means lenders and brokers are responsible for their own service proposition definitions, not each other’s.

Another key element centres around justifying the price set and how this works for different business models.

Sinclair said the crucial thing is whether the work differential enough to justify the fee, and if it is, are you allowed to add it to loan with the lender, which is something the lender may disagree with.

He said the debates around this would occur over the next two years.

He added there were multiple questions around how you demonstrate the customer has understood the product, how the lender feels comfortable that the broker or intermediary has “sold it in the right way”, and where the responsibility lies between the lender and the broker.

Sinclair this could raise questions about whether lenders may want to “limit and close off their distribution” as they want “assurance that those distributors really understand the product”.

“It becomes a really interesting problem about how we do this in this marketplace, particularly in the specialist marketplace. You have master brokers, instructors, and packagers that are specialists in space and therefore it works well. Is that the world we will have to model more on?”

He added that there were also questions around how feasible the 12-month implementation timeline would be and how the Financial Ombudsman would interpret it.

“They don’t have to think about what the rules are, as in the rules say we’re allowed to do this, so I’ll judge what’s fair and reasonable. That is not a structure that is sustainable in the long term with PII (professional insurance indemnity) cover in the shape it’s in at the moment,” he said.


Appointed representative regime in FCA sights

Sinclair said the regulator decided the current AR regime is “fractured and broken” due to actions in other sectors.

The FCA launched a consultation into the AR regime to address a “wide range of harm” caused to consumers. This includes inadequate due diligence in appointing an AR, as well as insufficient oversight and control post-appointment.

He continued that draft definition for upcoming AR changes centred on the regulatory hosting definition, which allows businesses to carry out regulatory activities without directly being FCA approved.

Sinclair said using this definition could force networks to have something in-house around advice so they can evidence they are doing some of the advice or will there be mortgage market exemptions.

“Not many networks want to start doing the advice themselves because the model is built on the fact that they provide the infrastructure and tools,” he said.

He added that another concern from the regulator was that some ARs are “too big”, with one suggestion being that AR firms over a certain turnover firms may have to become directly appointed.

Sinclair pointed out this could be very damaging if certain ARs with significant income are forced to walk away from networks.

“We have business agreements that keep them tied in. But we have a regulatory contract that says you’ve got to leave. It doesn’t work in any understanding that I have of how regulation should work in the commercial world,” he said.

Sinclair continued that the concept of the self-employed could also change, as the regulator was “saying explicitly” that the principal firm should take total accountability on ARs “for the work they do under your licence, and for anything they do that you should not be allowing them to do”.

The British Specialist Lending Senate 2022 in pictures

The British Specialist Lending Senate 2022 in pictures

AMI says FCA fees consultation reveals ‘serious disconnect’ with mortgage market

AMI says FCA fees consultation reveals ‘serious disconnect’ with mortgage market

AMI’s chief executive Robert Sinclair (pictured) said that whilst there was a “good three-year plan and business plan” there was still a “serious disconnect” with its approach to fees.

He called out the proposal to increase the AR levy on networks by 14.8 per cent, which he said had been hidden in the rules. The detail can be found on page 18 of its 101-page consultation paper.

The current levy is £250 for each AR firm a club or network has, and the consultation suggest increasing this to £287.

He said surcharging networks a further 14.8 per cent on ARs “for issues that exist in other markets, continues to cause us significant concern”.

Sinclair also criticised the significant rises to the minimum fee that will be implemented over the next two years and the flawed assumption that firms can pay for the FCA’s National Insurance increase via hiked up fees.

He also condemned the decision to charge mortgage brokers for new work for cryptocurrency, which is a “scope change” project by the regulator to bring select cryptoasset businesses under the Money Laundering, Terrorist Financing and Transfer of Funds Regulation of 2017.

“The assumption that mortgage broker customers can find the money to pay for the process to review and authorise cryptocurrency firms displays a total lack of appreciation of the thin margins that most brokers operate under,” he said.

Sinclair added that the five-week consultation period was inadequate, calling it the “shortest in memory”.

The consultation period for fees at the FCA opened on 7 April and is due to close 12 May.

The FCA fees consultation operates on an annual cycle with the regulator consulting on periodic fees rates, as well as changes to application fees or other fees, for the next financial year in March and April.

It also consults on the Financial Ombudsman Service (FOS) general levy, the Single Financial Guidance Body levies and illegal money-lending levies for the next financial year.

In its business plan, the FCA said it was making changes to “improve principals’ oversight of their ARs, increase the information they give us and raise standards across financial services”.

Sinclair continued: “I am infuriated by the arrogance of this new fees consultation. The impossibility for anyone to hold the FCA to account is becoming damaging to the industry.”

He added that the senior team at the FCA said they hoped to have more time to engage with the industry in 2022 than they had during the Covid crisis.

“It is to be hoped that there is enough of an industry left by then, as the increasing regulatory cost burden makes this a less attractive place to be,” he said.

“It is death by a thousand cuts, with increasing FOS fees, FSCS [Financial Services Compensation Scheme] costs, Consumer Duty and the raw cost of the FCA activity and fees. Good firms cannot just keep having an escalating bill.”


Morgan Ash launches FCA compliant client vulnerability rating tool

Morgan Ash launches FCA compliant client vulnerability rating tool


The FCA’s ‘Guidance for firms on the fair treatment of vulnerable customers’ came into force in February 2021 and will be strengthened by the ‘A new Consumer Duty’ paper, which is currently out for consultation.

The MorganAsh Resilience System (MARS) allows mortgage advisers and firms to meet the 2021 FCA requirements for understanding and managing consumer vulnerability by giving a ‘resilience rating’ score out of ten, similar to a credit score. MARS is independent of both providers and products, and can be used by anyone in financial services, for any product or service.

Andrew Gething, managing director at MorganAsh said: “Just as a credit score is used to simply communicate wealth, MARS is used to communicate health and resilience.”

MARS works by collating multiple data points from consumers and their advisers, including health, life events, and personal wealth. The rating is then matched to the stage of engagement and the potential for consumer detriment.

The system works for all finance businesses, but for a high-risk or high-value product, such as mortgages and later life lending, more detailed information would be required, which is then independently verified. The client can either complete an online questionnaire or, if they are suspected to be vulnerable, they can be booked for an assessment with a MorganAsh nurse. Mortgage and financial advisers can input a client’s vulnerability information themselves too.

The objective measure provides consistent and essential evidence of regulatory rigour to compliance teams and the FCA. It can be used as a standalone tool, or integrated with a firm’s CRM via secure API links. MARS is already integrated with systems from Intelliflo and Iress, with more integrations planned. It is also being used by St James’ Place and its partners.

Robert Sinclair, chief executive at Association of Mortgage Intermediaries, said: “Firms need to understand the characteristics of their customers, and be able to manage and report the conduct risk. Firms’ progress to-date has largely been limited to subjective individual assessments which risk inconsistency and complexity in recording.

“A move to more structured assessments that can provide consistent and objective data will provide management information that firms can utilise. The resilience rating within the MARS tool would appear to be a positive first step.”

Keith Richards, chair of the Financial Vulnerability Task Force, added: “Given the often complex and technical nature of financial planning – which automatically places most people in a position of vulnerability because of knowledge and experience-based dependency – we must do what we can, at every opportunity. The current regulatory focus on vulnerability provides a timely opportunity to improve how we can recognise and address vulnerable circumstances, whilst also demonstrating individual care and empathy.

“Good practice principles and the use of fintech, such as the MARS tool, can greatly improve our ability to assess, store and communicate vulnerability across and between organisations.”

Iress, Mortgage Brain and Twenty7Tec team up to standardise mortgage terminology

Iress, Mortgage Brain and Twenty7Tec team up to standardise mortgage terminology

The technologies share data between broker software and lender portals with the aim to speed up mortgage decisions in principle and application processes.

The firms hope to remove barriers and any misconceptions brokers have around embracing technology by standardising the language and terminology used. 

It is also supposed to make the platforms easier to use and improve the customer journey. 

This will be enabled with Mortgage Connectivity, a program which is already used by 20 lenders to encourage consistent data transfer. The collaboration has been supported by Accord, Leeds Building Society and TSB, who will review the way their technology partners communicate with brokers too. 

Davie Miller, Iress’ executive general manager, commercial, said: “To date, lenders and technology platforms have used a wide variety of terms to describe the same process. Clearly this is hugely confusing for brokers and can block the wholesale adoption of processes that can significantly improve the speed and efficiency of mortgage applications and decisions.  

“It’s a problem faced by the whole industry and coming together as an industry was the only way to solve it.” 

Nathan Reilly, director of lender relationships at Twenty7Tec, said education and collaboration were both essential to efficiency and time saving.  

Neil Wyatt, Mortgage Brain’s sales and marketing director, added: “It is crucial that we work in collaboration when it comes to ensuring we are able to deliver the best possible outcomes for end users, regardless of the product, the technology being used, or the size of the firm using the technology.  

“We are excited about how this will help and support individuals and firms across the marketplace adopt the available and developing technology and ultimately drive significant customer benefits.” 

Robert Sinclair, chief executive of the Association of Mortgage Intermediaries, said: “AMI has advocated for some time the need for technology firms to work together to provide solutions that embrace more of the customer journey.   

“This collaboration between our three main sourcing engines has to be seen as really positive and hopefully the start of a longer journey.” 

Top 10 most read broker stories this week – 11/03/2022

Top 10 most read broker stories this week – 11/03/2022

Commemorating a decade of the Association of Mortgage Intermediaries and how to better engage with clients were stories which also held readers’ interest.

Mortgage rates rise as lenders pull deals off market – Moneyfacts

Just Group posts pre-tax loss of £21m following lifetime mortgage disposals

Landlords brace themselves for higher rates with longer term fixes, brokers say

Buy-to-let sector is ‘changeable lending environment’ – Armstrong


A decade of AMI: The biggest achievements, changes and upcoming challenges – Sinclair


Brokers still lean on their own knowledge with the aid of sourcing tools – Marketwatch


Swap rate and mortgage price environment is a complicated picture – Gee


Rising house prices spark interest in affordability – Firth


Brokers reveal how a market niche sent business booming


Engaging with clients is priority #1 for advisers – SimplyBiz

Paradigm promises to match donations to support Red Cross in Ukraine

Paradigm promises to match donations to support Red Cross in Ukraine


The mortgage distributor has set up a Just Giving page to accept donations which will go directly to the British Red Cross Society’s appeal to help the Ukrainian Red Cross.

Paradigm’s parent company Tatton Asset Management plc has pledged to match donations made via the page, which can be viewed here:

Paradigm is also working with the Association of Mortgage Intermediaries (AMI) on the fundraising campaign to reach the wider industry and provide more support to those caught up in the war in Ukraine.

All money will go to provide food, medicine, clothing and shelter, as we all as first aid training in bomb shelters. The Red Cross has continued to distribute food and hygiene parcels plus thousands of litres of water since the fighting began.

Paradigm has asked its members and all stakeholders within the advisory community to share details of the appeal or other campaigns to raise funds for the people of Ukraine.

Bob Hunt, chief executive at Paradigm Mortgage Services (pictured), said: “To witness what is happening in Ukraine right now is truly devastating. We’ve been looking at different ways we can support the Ukrainian people whose lives have been turned upside down by this illegal war perpetrated upon them by Russia.

“We’ve therefore teamed up with AMI to set up this Just Giving page to accept donations to the British Red Cross appeal for Ukraine which will directly support their incredibly important work right across the country.

“We’re also pleased to say that Tatton Asset Management will be matching these donations, helping to raise more valuable funds for these individuals.

“Many people will already have donated in a number of ways, but if you’ve yet to do this, we’re asking all those associated with our industry to show their support for the Ukrainian people whose lives have been turned upside down by these events.”

Robert Sinclair, chief executive of AMI, added: “The humanitarian disaster being created by the conflict in Ukraine should be of concern to us all. The movement of millions of women and children across Europe is going to create a need for aid at levels not seen in Europe since WW2.

“The British Red Cross has the expertise, capability and capacity to provide direct assistance to those most in need, where hopefully they can operate under a flag of safety. AMI is supportive of initiatives promoted by firms such as Paradigm for those who want to express their support in a tangible way. We will be sharing this solution with all our membership.”

A decade of AMI: The biggest achievements, changes and upcoming challenges – Sinclair

A decade of AMI: The biggest achievements, changes and upcoming challenges – Sinclair

Speaking to Mortgage Solutions on Association of Mortgage Intermediaries’ (AMI) 10-year anniversary, chief executive Robert Sinclair (pictured) said the trade body had made several key achievements and witnessed dramatic change in the mortgage market.

AMI was founded in 2003 and was previously part of the Association of Independent Financial Advisers (AIFA) but became a separate entity in 2012.

The MMR, which was proposed in 2009 and came into force in 2014, fundamentally reformed the mortgage advice market, requiring tighter qualifications of sales staff, tougher rules on affordability and interest-only mortgages and a ban on self-certification mortgages.

He said: “Working to try and get the right angle [and wording] was really important, we were all lobbying and having rows about what the right answer to the problem was.”

He added that while it had brought in the “pain of the stress test”, looking back it had “served us well” and was a “real positive”.

Sinclair noted: “If we had thrown the kind of money that’s been thrown at the mortgage market by government through the [health] crisis, if there hadn’t been stress testing god knows what house prices would be now.”

He continued that another key area the trade body had worked on was talking to the EU Commission on how to structure legislation so it “would not fundamentally damage the UK mortgage market”.

“We wanted to give time and flexibility around ESIS implementation, so lenders had time to make the changes and so they did not have to invest a huge amount of money quickly,” he said.

He said it was very challenging as it was “trying to build something that fits 27 countries, 26 of whom do not have intermediaries”. He said in other European countries, mortgages and insurance were typically it was done by direct selling rather than through mortgage brokers.

He added that another key achievement  the trade body had worked on a was document called “Working Together”, which was born out of Treating Customers Fairly work done with the Financial Conduct Authority (FCA) and its counterparts. It defined the rules and responsibilities of the lenders and brokers.

Sinclair said: “It was a huge piece of work. The hard work wasn’t getting it published, it was getting everyone around the table to discuss it and agree.”

He said the document went through six iterations before it got agreed, partially because participants were “taking it back into their firms and talking about it”.

Another big achievement of the trade body was helping to change the funding structure of the Financial Services Compensation Scheme (FSCS), so mortgage brokers were moved from the pensions class into the general insurance class.

He said the change had saved mortgage brokers around £500m over the over seven or eight years since the change was made.

He added that another “big win” from that consultation was making lenders must pay for 25 per cent of home finance intermediation claims.

“Not only did it mean that they had to make a financial contribution, but it also focused their minds to actually manage their distribution better otherwise there’s a penalty for it,” Sinclair said.

Sinclair added that in 2019, the FCA had removed around 100 mortgage brokers, and the industry had continued to do so, pointing to Lloyds Bank Group and RBS’ removal of 2,000 brokers partially due to the above changes.

He added that another key aspect of AMI was to build relationships between lenders and brokers. Sinclair said in other fields like insurance and investments, “brokers” and “lenders” in that space were “almost like enemies”.

However, he said whilst this had been the case to a certain extent in the mortgage market, especially before and during the financial crisis of 2007 and 2008, the market had “transformed”.

“That’s been really important for us over the last decade, that we’ve tried to work in partnership with the lenders and look at what’s best for the industry and best for the customer as opposed to just worrying about what’s best for us. It’s about forming an allyship and support as opposed to fighting.”


Biggest challenges

Sinclair said the three big “knotty problems” with the regulator looking forward were the FCA looking into consumer duty, the future role of networks, as well as potential changes to the FSCS.

He said AMI was taking part in the FSCS consultation again and would push for lender contribution to be 50 per cent so it was equally split between lenders and brokers.

From a government perspective, he said the cladding crisis was still an “absolute disgrace” and AMI was “staying close with the discussion” by talking to UK Finance, Building Societies Association, Association of British Insurers and the Royal Institute of Chartered Surveyors.

However, he added that these parties, along with the government, were the people who make “fundamental changes”.

“The lenders know what the issue is, as do the surveyors and the insurers. The broker or consumer viewpoint is not going to change the real mechanical issues that they’ve got of who takes responsibility, who pays and who sorts it,” he said.

Sinclair said leasehold reform was another key issue, and although progress had been made on escalating ground rents more needed to be done.

He said later life lending would also come under scrutiny as the population was ageing and assets would increasingly be needed to fund peoples’ retirement because pensions would be insufficient to maintain their current standard of living.

He added that many pension funds were also the funders of later life lenders and said there was a “big drive” into the lifetime mortgage market.

He said over the past three or four years there has been “more money chasing [fewer] consumers than they have funding for” which he said was “relatively unusual”.

“We have more supply of assets looking for a borrower, and that’s never a good place to be,” he said.

He added that from a consumer perspective, he would estimate that around 90 per cent of people considering lifetime mortgages or later life lending could be vulnerable and he didn’t see evidence of that being accounted for in current processes.

Sinclair said: “My worry is that the industry has continued to hide behind ever escalating and tightening standards coming from the Equity Release Council, which gives them a comfort but if they tick all the boxes, I’m set. That is nowhere near where they need to be.”

Sinclair said the association’s Viewpoint report, which surveyed attitudes and experiences to diversity and inclusion in the industry, would also hopefully lead to some notable changes.

He said 45 people, from both broker firms and lenders, wanted to work with the trade body on carrying through changes as a result of this. He said there would be three working groups who would work on actions.

“It’s really about not letting any of this go. It’s about making sure that having created this level of interest and opened up the debate you still allow this debate to happen in a climate of safety and inclusivity,” he said.

He added that it was fundamental that white middle-aged men were also involved in diversity and inclusion efforts, otherwise change would be stymied.

Sinclair said: “It is fundamental that you’re inclusive and that you’re seen to be wanting to be part of this, otherwise it becomes it becomes the minority fighting against majority still. If it’s a minority working with the majority, it becomes inclusive.

“There are no silver bullets. There’s no easy way of doing this.”


Affordability test removal badged broadly positive for borrowers – analysis

Affordability test removal badged broadly positive for borrowers – analysis


The BoE introduced two recommendations in 2014, one around loan to income ratio (LTI) which states that 15 per cent of the total number of new residential mortgages should not have a LTI ratio at or greater than 4.5. This applies to lenders whose residential mortgage lending is above £100m per year.

Its affordability test says borrowers should be able to afford their mortgage if their mortgage interest rate is three per cent higher than their reversion rate, in the first-half of next year.

The BoE said in December that it would consider withdrawing the affordability test

Earlier today the BoE’s Financial Policy Committee (FPC) launched a consultation on the mortgage affordability test and said that the LTI limit had a “stronger role” in guarding against an aggregate household indebtedness and the number of highly indebted households.

It added that the affordability test could have limited the borrowing ability of around six per cent of borrowers, or around 30,000 applicants per year.

Kate Davies, executive director at the Intermediary Mortgage Lenders Association (IMLA), said that that the announcement of a consultation to remove the affordability test was “no real surprise to the sector, but is still very welcome”.

She added: “For some time, IMLA has been arguing that the combination of FCA Mortgage Conduct Of Business (MCOB) rules, LTI limits and the three per cent stress test have placed unrealistic demands on borrowers when compared to the rates they have actually been paying, or could expect to pay.

“We are particularly interested in the FPC’s analysis that the LTI flow limit is likely to play a stronger role than the affordability test in guarding against household indebtedness, and we shall be considering each measure’s relative effectiveness carefully as we develop our response to the consultation.”

Robert Sinclair, chief executive of the Association of Mortgage Intermediaries, said that the BoE might be keen to remove the affordability test before the end of Help to Buy, which is due to expire next year.

He explained: “I think that there’s always the continual issue of the deposit, which is the first hurdle you’ve got to get across. For instance, if you’re renting and trying to save at the same time, and add student debt, how many barriers can we put in the way?

“Then there is the next element of affordability hurdle that then becomes a bigger issue particularly for the South and with the loss of Help to Buy, which has been a big help in the market. I think this is this is the change [it] feels comfortable to make in order to try to keep the market moving in the right direction.”

He added: “I think the other part is if you take this off [the affordability test], it might allow others to borrow more. It will have a broader impact across the whole market as opposed to just those who are currently excluded.”

Paul Broadhead, head of mortgage and housing policy at the Building Societies Association, said: “We welcomed the FPC’s intention to withdraw the affordability stress test for new mortgages when it was first announced in December 2021 and still do. This measure primarily impacts borrowers such as first-time buyers and those looking to buy in the South East, who can clearly afford a mortgage.

“Lenders will continue to follow existing rules, including those in MCOB, to check that a mortgage is affordable both now and if interest rates continue to rise in line with market expectations. We are consulting with our members on the specific questions raised in the consultation published today.”


Questions raised for lenders


Nicholas Mendes, mortgage technical manager at John Charcol, said that scrapping the affordability test would be “welcomed by homeowners and broker alike” and that this could be a boost for the market given rising property prices.

“It will be interesting to see how much this will mean, given at the time of rules changing, we are expecting to see inflation continue to increase into 2023, and with multiple base rates rises, lenders could choose to not make any changes. Predicting where rates could be in five years’ time seems almost impossible.”

Mendes added: “Any changes depending on how lenders react will benefit in the short term as buyers have increased affordability muscle in negotiating on a home. Longer term, homeowners would be in the same boat, so broadly speaking no individual homeowner would be better off. What we might see is people bidding higher and/or  increasing offers, as a result this risks the same homeowners that would be buying the same properties but at higher values.”

Mendes said that the potential removal raised questions about how lenders might change the way they calculate affordability. He said lenders who use Office of National Statistics (ONS) as the basis for affordability calculations could lead them to review the calculation more regularly and that lenders who trialed this have seen maximum borrowing reduce for homeowners, highlighting a growing concern about those who are currently on shared ownership schemes.

“Based on previous calculators those on the scheme based on potential future affordability modules wouldn’t be able to afford the borrowing that they original took out.”

He added: “Any stress rates changes may mitigate any potential changes if calculations do change as lenders look at ONS stats, it will be interesting to see what lenders do between now and the 17 March in terms of their communication with brokers, and what lenders do after the announcement.”

Mendes added that rising cost of living, increasing energy and fuel costs and Brexit could led lenders to “exercise caution and start to consider other factors to ensure the mortgage remains affordable”.

David Hollingworth, associate director of communications at L&C Mortgages, said: “There’s clearly no desire to remove restraints that could result in a move back to the looser lending standards that were in place in the run up to the financial crisis. However, we do have a belt and braces approach at the moment with the stress rates and LTI limits in place. The stress rate does give some natural space for borrowers to be able to deal with higher rate environments than when they take the initial mortgage.

“However, although stress rates help prepare for rising rates, they keep moving as rates change as well, as is currently the case so it can be a moving target. The FPC seems to suggest that altering the impact on affordability shouldn’t result in so much more leeway that borrowers could be put in harm’s way, so we may find that there’s limited impact and both limits have done their job.”

He added: “If it gives some borrowers, for example first-time buyers, a little bit more flexibility to borrow enough to deal with the pressures that high prices present without throwing the principles of affordability out of the window, it might just help a few more borrowers get the mortgage they need.”