Response - FSA Arrears and Approved Persons

By: Nicola Hughes  Published: April 2010


A stronger regulatory stance on arrears and repossessions is long overdue. The FSA’s thematic work and our own casework and research have repeatedly shown instances of lenders failing to forbear and treat struggling homeowners reasonably, particularly in the sub-prime sector. We are concerned that a rise in interest rates and the effects of unemployment will mean that arrears remain widespread throughout 2010-11. In this context, regulation must ensure that struggling borrowers are treated fairly.

Summary

We recommend that:

The proposals must be implemented as soon as possible to improve outcomes for the many thousands of borrowers who are likely to struggle in 2010-11.The FSA must hold true to its commitment to ‘move quickly’.

The FSA needs adequately resourced and stringent monitoring and enforcement procedures if the proposals are to be effective. Some of the proposals on arrears management handling do not go far enough – we would like to see even tougher rules proposed for MCOB 13.

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