I remember, shortly after joining the network, Jennifer interviewing me for The Right News (August Edition) and asking what I aim to achieve in the first 6 months. Well, first and foremost (and always) it is to ensure that as a network, as firms within the network and as individuals, we put customers at the heart of everything we do. We talk a lot about trust and respect and there is no doubt that this fosters a strong working relationship. Through my many (many) conversations and meetings with advisers over the last few months I have no doubt that, as a group, you deal with customers in a fair manner and that you put the customers best interests first. I have a great deal of respect for you in demonstrating this through the conversations you have with my team and through the record keeping in general. As a network we have created a solid platform for you to operate within, with good systems to help you deliver a great customer experience; to offer the best range of products and to ensure that the customer gets the perfect deal that meets their requirements.

I have worked hard to increase awareness on the some of the key issues in the market today, the things that cause a threat to your business – not least the importance of following the correct sales process and being vigilant for fraud and financial crime.

In this time we have reintroduced disclosure documents, revised customer declarations, created buy to let and protection disclaimers, updated the suspicious activity reporting process and the product transfer process, offered an electronic ID verification solution and an off-panel process. Oh, and there is the new T&C Scheme to be launched in the New Year.

We’ve built a strong team of compliance professionals who have been selected for their knowledge and experience, but also for their ability to build relationships and work in a trusting and respectful way.

So, on reflection, I’m really pleased with how things are developing and I am grateful for the fantastic feedback I have received during that time – especially during and after the recent Conference.

There is more hard work ahead and I hope you appreciate the changes as they happen.

Training & Competence

In recent weeks I have talked about the new T&C Scheme to be launched in January and next week I will publish the full T&C document. It is important that you understand the requirements of the scheme, what is to be expected of you, the measures that are made in regard to your ongoing competence and the impact of these, so, by publishing the scheme early, you will have a good 4 months to ensure that you understand this before the first set of measures are taken at the end of Q1 2016.

Last week I referred to the performance measures and introduced these measure to you and the concept of a quarterly risk rating. This process will be overseen by your compliance manager, who will support you where the measures identify any areas of risk, or where knowledge needs developing.

Two of the most important measures, in my view, are the file review outcomes and the business quality feedback we receive from our product partners and much of our attention will focus on these key areas.

In addition to this quarterly review we will perform an annual assessment of the overall fitness and propriety of individuals, which will focus greater attention on firm principles (directors/owners) in line with the regulators expectations. These annual reviews will include knowledge testing as well as financial checks on all advisers and approved persons. It is important therefore that if you are suffering any financial issues that you self declare and report these to your compliance manager.

Before I finish on this topic, and ahead of us publishing the full scheme next week, I wanted to mention that we will commence a process for engaging with customers through a short questionnaire so they can have an opportunity to let us know about their experience and if they feel that there best interests have been considered. To make this an easy process (and cost efficient) we will be looking to do this through electronic means, so I would ask that you gather and input customer email addresses into the Key.

Mortgage Credit Directive

One of the requirements introduced by the MCD that will have a big impact on the lending industry is the inclusion of second charge (mortgage) lending within MCOB rules. In the current market, second charge (or ‘secured’) loans are often considered an expensive alternative, if indeed they are considered at all. Experience tells me that most brokers wouldn’t even consider a second charge loan and this is largely down to their knowledge, ease of access to rates/products and confidence in the referral system.

From 21st March 2016 the rules will compel mortgage advisers to consider second charge loans alongside first charge mortgages, so these issues will need to be overcome.

We will work with you to overcome any product knowledge gaps, and this will be supported by product providers who specialize in this market.

Traditionally the market has been dominated by master brokers and, there is no doubt they will continue to play an important role, but we will see greater support from lenders who wish to offer their products directly to brokers. This is great news and will create more competitive solutions. New rules will mean that loans with expensive, up-front costs, will be replaced by loans with fees that have to be ‘reasonable and justified’.

And for those not confident in referring clients to a broker, we will be creating an advised sales process that keeps you in total control and provides you access to the resources you will need to search and compare the market, produce the ESIS document and complete the paperwork with your customer. We will also ensure you have a choice of really good firms with whom to operate, either as master brokers, or on a more direct basis.

We aim to do focussed training within this area in January and this will supported by practical sessions during the winter conference, well in advance of the 21st March implementation.

Running update

I mentioned a few weeks back that I was lucky enough to secure a place in the 2016 Virgin Money London Marathon, taking place on 24th April, and I am really looking forward to the event, even though it’s a good 5 months away.

I only started running last November and, as a 46 year old, I found training for the last London Marathon really tough. The fact is, though, that the 500 training miles were well worth it and taking part was one of the best experiences of my life. I could have stopped there (and often wonder why I didn’t), but I’ve kept it going and this weekend (28th November), having done another 700 miles of running through the summer and autumn, I shall be running my second marathon around the lovely town of Newark on Trent. This one is not for charity – just for fun (!)

After this one I’m going to take a full month off and do some serious ‘carb-loading’ (I love mince pies) before I get cracking for London 2016. Look out for my updates in the New Year as I embark on the ‘road to London’.