It's The Final Countdown
There are many, many things from Europe that I would love to welcome to the UK; sunshine, afternoon siestas and premium strength beer as standard. One thing, however, that I am not as keen on seeing imported is European financial services regulation, like the Mortgage Credit Directive (MCD).
The MCD will affect everyone involved in the rapidly growing second charge mortgage market. Until now, this type of business has been regulated under Consumer Credit permissions and therefore brokers haven’t needed to be authorised for mortgage activities. However, when the MCD finally becomes an official part of UK regulation from the 21st of March 2016, everyone conducting second charge business will need to have the relevant permissions in place – granted by the FCA –, or will be trading illegally.
It’s worth bearing in mind that the Mortgage Credit Directive is founded in a Europe-wide initiative and, consequently the timescale for implementation is not the FCA’s. This brings some real life implications for firms as they undertake the application process: those arriving at this point via Consumer Credit Interim Permissions will be familiar with their three month application window and will also know that, provided they submit and have their application acknowledged by the closing date, they can rely on Interim Permissions until the FCA process is complete (one way or the other!). However, when it comes to the MCD, the application needs to be processed and permissions in place by the 21st of March next year or you will not be able to trade legally. There is no equivalent of interim permissions for the MCD – it’s all or nothing.
Applying to the FCA for authorisation is a lengthy process; you don’t need me to tell you that if you haven’t already, you need to begin now. Apologies if this sounds like scaremongering, but I feel it’s essential to emphasise how important this is; you need to apply for your MCD permissions now or you may not be able to trade legally after the 21st of March 2016. Our expert applications team is able to advise you on how to meet this business-critical deadline and ensure you can continue to trade on 21st March 2016.
The SimplyBiz Group, of which the Consumer Credit Centre is a part, has many years of experience and a highly skilled specialist team, and that’s just one of the reasons why AOBP has chosen to partner with us. If you want help with applying for permissions or changing your application date for consumer credit authorisation, please get in touch with us urgently on 01484 443424.
David Golder
Managing Director
Consumer Credit Centre
SimplyBiz Group