KNOWLEDGE

The FCA on mortgages, Covid-19 and consumer outcomes

Morton Fraser Associate Catherine MacPherson
Author
Catherine MacPherson
Senior Associate
PUBLISHED:
22 October 2020
Audience:
category:
Blog

On 30 September 2020 Jonathan Davidson, Executive Director of Supervision – Retail and Authorisations, at the FCA delivered an introduction to Mortgage Forbearance Webinars. The speech was published on 8 October 2020. So what did he say and what can we learn about what the FCA expect when it comes to mortgages, Covid-19 and enabling positive consumer outcomes?

The idea behind the webinars was to help firms prepare for the next phase of support being afforded to mortgage customers suffering from Covid-19 related detriment. This came at a time when firms are moving away from the crisis mode of reacting to Covid-19 related issues and moving towards tailored support for customers. Pivotally when we're all trying to work out what the new normal will be, it's likely that BAU (business as usual) in financial services will not be what it was pre Covid-19.

Whilst Jonathan Davidson recognised the "world of shifting sands" and the "amazing job delivering a huge number of mortgage payment deferrals" in the industry, he highlighted that there will be "a significant minority of customers who will face ongoing difficulties through this unprecedented period."

With Covid-19 affecting so many people in different ways and it different times the FCA understand that firms are facing operational challenges. There is a call for the industry to continue to work together and deliver solutions. The industry is expected to continue adapting to new challenges. The quality of these changes will be monitored with a focus on consumer outcomes.

The expectations

The FCA expect that firms are:

  • actively planning how they will resource customer-supporting functions
  • actively planning how they will ensure that training and competence frameworks are effective, and how staff are monitored and mentored
  • looking at how they can ensure staff are adequately supported working from home when dealing with customers in financial distress
  • monitoring any third-party firms to whom activities are outsourced to make sure good customer outcomes are being delivered
  • prioritising support for borrowers that are most at risk of harm, or who face the greatest financial difficulties
  • delivering outcomes that are right for individual borrowers rather than adopting ‘one size fits all’ solutions
  • ensuring that where digital solutions are adopted they deliver appropriate outcomes, in a way that supports customer understanding
  • ensuring that more hands-on support is available for those that need it
  • making communications clear, this includes making journeys easy to follow for all
  • signposting additional appropriate support
  • identifying and acting on customer vulnerability
  • ensuring customers understand the implications of the option they agree to, especially where they have been through an automated process
  • acting quickly and fixing issues so that customers are put back in the right position

If the expectations are not met

The FCA will be monitoring firms and positive consumer outcomes. If there are significant issues then the FCA will intervene. Where it is that clear firms are trying to do the right thing the FCA want to work with them to resolve issues. The FCA recognise that Covid-19 "is affecting many aspects of customers’ lives - their health, their employment and their finances … Many borrowers will be facing a loss of income, over differing durations - and solutions may need to reviewed regularly as their circumstances change". Continual change appears to the theme for now.

Disclaimer

The content of this webpage is for information only and is not intended to be construed as legal advice and should not be treated as a substitute for specific advice. Morton Fraser LLP accepts no responsibility for the content of any third party website to which this webpage refers.  Morton Fraser LLP is authorised and regulated by the Financial Conduct Authority.