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Regulation and the buying process (Key Regulatory Stages (Disclosure at…
Regulation and the buying process
Key Regulatory Stages
Financial promotions, ie marketing of mortgages (MCOB 3A)
General Non-real-time financial promotions
Company details
Terms of promotion
Risk of repossession
APR
Competitor comparisons
Add. MCD Non-real-time financial promotions
Interest rate
APRC
Credit
Term
Instalments
Total
Examples
Real-time financial promotions
Hours
Contact
Identification
Check
Terminate
Content
Initial disclosure: meeting the adviser (MCOBS 4 & 4A)
Initial Disclosure information
Range of products
Unlimited
Whole of market products
Limited range
Limited range of products
Single lender
Only products from one lender
The firms remuneration
Fees charged
When fees are payable
Third party commission
Alternative finance options
Further advance
Second charge
Another mortgage
Unsecured borrowing
Providing Advice
Qualified advice
Interactive dialogue
Execution-only basis
High-net-worth customers
300k net income, 3m net assets
Professional customers
12 mths home finance exp.
Product knowledge
Risks involved
'Non interactive' channels (internet/postal sales)
Business customers
Sole purpose for small business
Providing advice (MCOB 4) and lending responsibly (MCOB 11 and 11A)
Income and Expenditure
Can't self cert.
Affordability requirements
Making an application (MCOB 5 and 5A)
Pre-application disclosure
Regulated mortgages
Key features illustration
MCD regulated mortgage
European standardised information sheet
Receiving a mortgage offer from the lender (MCOB 6 and 6A)
Regulated mortgages
Offer not binding on borrower/lender
MCD regulated mortgages
Final offer binding on lender
Existing MCD contracts offers not binding
Disclosure at the start of the contract (MCOB 7)
Amount and payment dates
Insurance premiums
Underpayments/overpayments
Type of mortgage
Interest only-repayment vehicle
Arrears procedure
Linked borrowing/deposit