DSC_0613One of the cornerstone processes for any financial services business is the program for training and competence – the T&C Scheme. In a network environment this is even more crucial as the T&C Scheme sets the methodology by which supervision is carried out between the network and the AR firm as well as with individual advisers.

I spoke briefly at the conference about my plans to introduce a fresh scheme, to be effective from the new year, and over the coming weeks, I will talk more about what the scheme entails, the key performance measures, the adviser risk rating process and the annual check on fitness and propriety. By the end of the year I will distribute the full scheme and our first set of quarterly risk ratings will take place at the end of quarter one, 2016.

T&C Scheme Overview

The Right Mortgage Training and Competence Scheme is designed with the principles of Conduct Risk, Treating Customers Fairly and the objective of providing the best customer outcomes in mind. These principles and objectives are inherent in the philosophy of the company and should be within the core values of advisers representing it. The T&C Scheme sits alongside other key documents, such as the FCA Handbook, the Right Mortgage & Protection Network procedure documents and the terms of the adviser’s contract of employment or engagement in ensuring that the network standards are met and maintained.

This T&C Scheme is not a strict, rule-based, scheme but one based on evidence and risk management principles to ensure that Advisers meet the company and regulatory standards.  The Scheme also recognises the importance of the FCA principle of “Treating Customers Fairly” as part of a supervision regime.

The key areas of activity for the scheme focus on:

  • Recruitment
  • Induction and attaining competence
  • Maintaining competence

The Right Mortgage has a team of Compliance Managers – Sarah Glenn, Maxine Levers-Riley and Ben Allen – who will oversee the T&C Scheme. Appointed Representative firms who wish to take on trainees can appoint a firm Supervisor to undertake the local training activities.

The T&C Scheme document itself, which will be published before the end of the year, summarises the minimum required activities and performance levels required for an adviser to achieve and maintain competency and provides guidance to assist the Compliance Managers and Supervisors with their responsibilities.  Whilst the scheme is prescriptive in certain areas, it is recognised that individuals have different abilities and experience and therefore a degree of flexibility may be applied.

T&C Scheme – Ongoing Monitoring

The Scheme details the steps taken for recruitment, induction and attaining competent adviser status (CAS). For many of those reading this update they will have already completed this, or be close to CAS already. Therefore it is more important that I detail what is required by each individual to maintain their competence and to achieve a good quarterly risk rating. These details will be provided in next week’s update.

Electronic Identity Verification

Last week I confirmed that we are happy to endorse the Sanctions Search EIV system and that details on how to register will follow. I had hoped to have these ready for you this week, but we are not quite there. Please bear with me, details to follow asap.

Conference Update

Wow – what a fantastic event. My first as a Director in the network and therefore the first chance to meet with many of you. I was overwhelmed by the positive comments on my presentation, in which I spoke to you about the T&C Scheme, the developments in my compliance team (what a team!), the Mortgage Credit Directive and what is on the regulatory radar beyond MCD. During the round table presentation Jane and I were able to convey the importance of submitting quality business and re-iterated the need to be ‘fraud aware’.

I have had a lot of great feedback, in particular, about the Fraud Aware document that was included in the conference packs. A copy of the document can now be located on the Document Library and we are building this into a module for our new induction training site, so new entrants are educated on these key requirements and will be tested to ensure they understand what is expected, helping us to keep our network safe.

Click here for the Fraud Aware document.

Mortgage Credit Directive

As mentioned at the conference I shall be starting a series of communications to the network about the Mortgage Credit Directive (MCD) – the implications this will have on the mortgage market and the changes this will mean to mortgage advisers, in practical terms. These will be supported by updates on the changes lenders are making by Jane Benjamin.

From a regulatory point of view, I will ensure that you understand the key changes, such as the impact on second charge lending, consumer buy to let, ESIS/KFI plus, binding offers, reflection periods and other details.

So, over the next few weeks, therefore, I will focus my updates on the new T&C Scheme and the Mortgage Credit Directive. Look out for me in your inbox!