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It may be going a little far to liken the FSA to the Scarlet Pimpernel but when it comes to mystery shopping the regulator is equally as elusive. While no one knows which firm the disguised consumers will target next, we do know it is likely providers and intermediaries face visits from mystery shoppers if they have not already dropped in to check on existing practices and procedures.
As part of its Mortgage Effectiveness Review, the FSA has looked at areas of the mortgage market where the risk of consumer detriment may be greater than elsewhere.
Although the regulator has said it will be taking a close look at the customer experience of those who have already secured products from these markets, it seems fair to assume it will also have a look at how products are being advised on and sold in the present.
It may be too late to do anything about cases that have already been completed but there is no time like the present to ensure future advice and sales bear up to regulatory scrutiny.
The only way for mortgage advisers to do this is to take a leaf out of the legal profession's book. Lawyers charge by the minute and have time sheets that allocate their days accordingly. If they do not record each and every conversation, email, photocopy or letter that pertains to a client, they cannot charge them for it.
Advisers need to adopt this diligent attitude to record keeping and ensure everything from the first "hello" to the last "goodbye", is noted down.
Alison Beeston, compliance and communications manager of Bridgewater Equity Release, has found many advisers in the lifetime and reversion markets are committed to the sector and are well aware of their responsibilities. However this does not mean there is room to be complacent.
She said: "The initial disclosure document has to be clear on the areas where advice can be given. Does the client understand the options? Are reversions discussed? If an adviser cannot advise on reversions then where would they refer clients? Are there systems in place to show how advisers can introduce clients on?"
Of course not every client visiting an adviser about equity release is going to want a home reversion, but Ms Beeston uses the point to highlight the fact that advisers must be aware that all of a client's options have to be considered and where a lifetime mortgage is not suitable the adviser needs to offer information that will help them make the most appropriate decision for their circumstances.
It is also important to highlight where and how products are sourced and make sure they are suitable for the exact needs and requirements of every client.
Kirsty Jackson, head of lifetime mortgages for Mortgage Express, said: "Advisers need to record details of why they are choosing the product, consider the other options, make sure clients have spoken to their families and discuss a client’s plans for the future to make sure the product is suitable."
For those looking for further information on acting compliantly, Ms Jackson said contacting Safe Home Income Plans should be a priority for information on reversion schemes.
The Council of Mortgage Lenders also has good practice notes for those operating in lifetime mortgage sector while individual lenders carry guidelines to help advisers ensure they advise clients appropriately.
There is unfortunately no magic wand that advisers can wave to become compliant overnight, although the good news is that attention to detail and basic steps in terms of sound record keeping will ensure many firms can prove the high standards they are already offering clients.
Indeed much of the negativity that has surrounded the equity release sector in the past has meant that advisers here are perhaps more aware of their obligations than elsewhere.
Both Ms Beeston and Ms Jackson felt the need for specific qualifications to operate in the equity release market and the focus required to generate long term and sustainable business levels would also see the sector continue to perform well when the FSA's mystery shopper comes calling.
Five Seconds: Making sure all your records are up-to-date from now on is key to avoiding a nasty surprise when the mystery shopper reveals itself to be the regulator