Examples of good and poor practice: Mortgage intermediaries
We see these examples as a means of helping you think for yourself about how best to meet our high level requirements within your business. And, by publishing real life examples of practice on either side of the minimum standard, you can see how to draw the line in your business of what is and is not acceptable.
Management behaviours
Good practice
- Management conducted a gap analysis, benchmarking itself against the six consumer outcomes.
- Management presented its TCF policy to staff, including back office staff. They also tested staff's understanding of what TCF meant for them.
- Management proactively encouraged staff to give feedback on areas they felt could be improved to deliver TCF.
- Management regularly monitored commission claw backs for each adviser.
- Management appointed a TCF champion - who did not have responsibility for sales - to review practices and align with consumer outcomes.
Poor practice
- Sole traders feel that TCF did not apply to them.
- Management were unclear about what TCF meant for their firm.
- Management unable to differentiate between a satisfied customer and one that has been treated fairly.
- Management monitored its sales staff on volume of business only, rather than quality of advice.
Sales and advice
Good practice
- Interest-only mortgage customers were provided with comparisons and costs of a repayment mortgage so that the he/she was aware of how much it would cost to convert at a later stage.
Poor practice
- Firm did not review contracts at the end of the incentive period.
- Advisers did not collect sufficient information on a client's credit history and instead relied entirely on a packager to conduct a credit search and come up with suitable recommendations.
Complaints handling
Good practice
- Firm conducted an analysis of the root causes of the complaints it had received. These revealed a training need for several advisers in relation to information gathering for sales of sub prime mortgages. As a result the firm introduced training for all advisers.
Poor practice
- Firm had no complaints procedures and had zero tolerance of complaints. This led to complaints being buried by advisers.
