Monday, 19 October 2009

Affordability checks for UK mortgage lenders - not so new

The UK Government and the FSA are making a great play of their plans to introduce affordability checks for mortgage borrowers. The FSA's reform proposals are here.

This really should be nothing new for the banks, which already have responsibilities under the FSA's Treating Customers Fairly initiative. The FSA Treating Customers Fairly pages include six consumer outcomes, including:
Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Drilling down further into the examples, these include a specific example of the need for the mortgage sales process to check affordability.

Affordability will often have been an issue in some types of loan, but these - self-certification, sub-prime and high Loan To Value mortgages - have pretty much disappeared from the market.

Best practice sales processes for lending already include the checks, but of course these are only as good as the information available to them, and some may be circumvented by inaccurate statements or disclosure by potential borrowers. If the proposals include harsh penalties for selling unaffordable loans, lenders will have a problem. Inevitably though, they will find ways to manage and mitigate the risks, even if that means a reduction in the availability of loans.

More later when I've gone through the 118-page FSA document.

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