UK Finance has published a set of principles for information sharing between mortgage intermediary firms and lenders.
The FCA has advised that it continues to see vulnerable consumers face challenges when disclosing their additional needs or personal circumstances to their financials services provider. This includes being repeatedly asked for vulnerability information, which the FCA’s guidance on the fair treatment of vulnerable customers expressly advises against.
UK Finance also drew attention to Consumer Duty requirements, and firms needing to have systems and processes in place to support and enable customers with characteristics of vulnerability to disclose their needs.
UK Finance has worked with the Association of Mortgage Intermediaries, the Building Societies Association and the Intermediary Mortgage Lenders Association to develop the principles, which focus on the customer journey from origination via a broker to a mortgage lender, within which which a vulnerability disclosure might be made.
The principles are voluntary, non-prescriptive and intentionally high-level. They are intended to help firms meet the regulator’s “tell us once” expectations, and cover:
- What, when, how and why
- Responsibility to declare vulnerability, and the point the customer relationship transfers to the lender
- Mortgage product transfers
- Joint responsibility for recording vulnerability