Consumer Buy to Let permissions
It has become apparent that some Lenders are declining cases due to the fact that the Broker does not hold the correct consumer buy to let permission. When applying for these the Broker firm should have selected “acting as a CBTL adviser” and “acting as a CBTL arranger”. If a firm had only selected one of these then this might pose a problem for the firm moving forward when conduction this type of business. Please check which permissions you hold by visiting the FCA website. These will appear in your basic details section on the register and not in the permissions section. If you do not have the correct permissions then you can amend your permissions using the following form free of charge: Amend your CBTL permission form.
The FCA are trying to process these requests immediately even though the response you will get from the form is a consideration period of 6 months. If this does take longer than 10 working days or you are charged for the privilege of varying these permissions then please let us know and we will take it up through our trade body the Association of Mortgage Intermediaries.
New Regulated Activity added: Advising on P2P arrangements
Some of you might have received an email from the FCA around a new permission that is being added to your profiles around the new Innovative Financial ISA which was eluded to in the Government’s Budget speech 2014. This new ISA would allow peer to peer lending agreements to be included within an ISA tax wrapper. This type of product is not a Retail Investment Product (RIP) so doesn’t affect firms calling themselves “independent” or “restricted” for investment advice under RDR rules. However if you have the permission ‘advising on investments’ which includes firms that have restrictions under these such as non-investment insurance contracts, which will be quite a few Mortgage and Protection only broker firm, you will probably receive this email. What you need to do is to look and see if your firm is going to advise on these contracts and if you are going to give advice to ensure you have the correct PI cover and competent advisors to do so. I would guess that most of you will not opt to have this permission added automatically and so therefore you will need to complete the form in the email to remove the permission. Here is the form for those of you who need it: Variation of permission notification form P2P
Mortgages Technical Director
Paradigm Mortgage Services LLP