Key Changes

We have designed a new fair value framework and have assessed our products through that framework. This assessment looked at each segment of our target market, with particular consideration to customers with characteristics of vulnerability. We have concluded through this assessment that our product range continues to deliver fair value for customers in our intended target markets.

We have adopted the industry standard Product Information sheet template, created by a joint Working Group comprising UK Finance, the BSA, AMI and IMLA, in order that you have a consistent view of our approach alongside the approach of other lenders.

We have worked to clearly define and communicate the customer groups each of our products are suitable (and not suitable) for. By doing this, we aim to help you to better understand and use our mortgage products, and to provide you with the information to demonstrate you have identified the most appropriate solution for your clients in your sales process.

We are in the process of developing and updating systems to better identify Vulnerable Customers and information about them. We will strengthen our help for Vulnerable Customers and provide you with support where appropriate. This will include making changes to our portal so you can record a customer’s vulnerable characteristics, and access to specific help with specialist communications.

We are reviewing letters that are sent to you and to your customers, including letters around mortgage offers and mortgage arrears. Our aim is to make the letters clearer and easier to understand.  They will be written in plain English and structured with clear subject lines and subheadings. We will keep wording required for legal or regulatory purposes. These changes should make it easier for you and your customers to identify any action needed. In addition, we are improving the customer help sections in our letters for those customers in difficulty who may need independent assistance.

We are updating our Intermediary Terms and Conditions to include the Consumer Duty requirements, as well as making them clearer. We will update our Intermediary portal with the new Terms and Conditions shortly, and we will let you know when we do.

Finova, the providers of our broker portal and back office systems, are making a number of customer focused system improvements, which will include functionality enabling you to record any characteristics of vulnerability your customers may have. These developments will also allow us to monitor those disclosures and offer appropriate support. We will be in contact to let you know how these changes affect you.

The FCA have instructed mortgage lenders to consider all costs and charges a customer may pay for a product when assessing fair value, including fees added by Intermediaries. Intermediaries distributing mortgage products charge a range of fees to customers. Mortgage lenders must assess whether these fees, when added to the lender’s product charges, may cause unfair value for the customer. We are reviewing the level of fees charged by intermediaries, when using our mortgage products and will provide further information prior to implementation of any changes. As always, you will also have the support of your Business Development Manager should you need to discuss further.