We’ve already introduced the ‘Offer Acceptance Form’ within the offer pack. Customers need to sign and return this form as evidence they’ve accepted a non-EMCD compliant offer.

We’ll shortly begin calling you if one of your client(s) has not returned their form.

From 25 January we’ll be introducing changes within our KFI and KFI offer documents (the KFI+), including a 7 day ‘right of reflection’. If we receive the COT within the 7 day period, we’ll take this as acceptance of the offer and waiver of the period of reflection.

At a later date we’ll introduce a ‘Key Points Explained’ letter which meets the ‘Adequate Explanations’ requirements of the directive.

What about Buy to Let?

Although Buy to Let lending is not regulated by the FCA, the EMCD will still apply to some cases. The EMCD has led to a new category of BTL Lending – ‘Consumer Buy to Let’ (CBTL).

We’ll soon stop accepting applications classed as CBTL. We define a CBTL application as a remortgage which has at least one applicant that meets all of the following criteria:

• The applicant(s), or a related person, have lived in the property since they first owned it;
• The applicant(s) do not own at least one other Buy to Let property which is either:
  • Financed by a Buy to Let Mortgage; or
  • Occupied by people who aren’t related to the applicant(s)

BTL customers won’t see any changes to their mortgage offer or KFI.

We’ll continue to keep you informed of all the changes we’re making in more detail, including updating our website, as we implement them.

If you need further information about these changes please contact our sales team on 0345 1200 866.