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Our Response to the FCA

We felt that we needed to respond to the FCA's alert about this site, though some of the advice is accurate most parts aren't. It is important to us to address the points that we disagree with. Right from the start we want to highlight the fact that we do not question the FCA's integrity in making these points, we just think that they are interpreting the rules incorrectly.

FCA: "Previously, when consumers took out a self-certified mortgage, they self-certified that the income stated in their mortgage application was true. Because of the harm caused to consumers in the past, this is no longer permitted in the UK"

Self Cert: There is no evidence Self Cert products caused any more harm than any other mortgage product available in the UK.

FCA: From 21 March 2016, all firms offering mortgages in the UK (including EEA firms) will have to comply with the Mortgage Credit Directive, which requires a thorough affordability assessment based on information that has been verified by the lender."

Self Cert: This is not accurate, the new directive by the European Banking Authority states that lenders should take all REASONABLE steps to verify income. We have never said that we wouldn't take reasonable steps. If the EBA wanted to insist on Self Cert's being prohibited, it would have used the same wording as the FCA does in the MMR. 

FCA: Under the ECD, firms can only contact customers on-line, not by telephone or post. This means you will not be able to speak to the firm about your mortgage arrangements.

Self Cert: This is also not true - well sort of not true. Whilst customers can not speak to the operations in Prague by phone or post, under the rules a company can outsource their customer services to a third party in the UK. The third party can give information about repayments etc, they just won't be able to give advice on mortgage products. Outsourcing customer services in this way is quite common, one example of this is Google who have a similar structure. Their sales team are based in the UK whilst the sale actually takes place in Dublin. The UK Government seems to be OK with this kind of operation.

The FCA is correct that people should proceed with firms based outside of the UK. It is our full belief that with increased regulation though sometimes erratic, businesses will seek to do what we have and choose a home outside of the UK. With mortgages the scope for problems are limited as the lender is the party that are risking their capital. Should that change to companies offering saving schemes outside of the FCA, we would certainly have reservations about the safety of such products.

We are very open about our set-up, we are more than happy to co-operate with the FCA, the Financial Ombudsman Service. We would even submit to their authority / arbitration in any area - other than telling us who we can and can't lend our own capital to.

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Self Cert is not based in the UK. We are NOT regulated by the Financial Conduct Authority

Prague 1, Czech Rep