However, with consumer perception responding positively to the ‘legitimacy’ of regulatory security and the strenuous efforts of second charge lenders to ensure that all related requirements have been implemented, there has been a welcome upsurge in borrowing levels over the past 12 months.
Indeed, according to the latest data from the FLA, new business loans increased by 10 per cent in the year leading up to December 2017, with total values increasing by 14 per cent.
In addition, the number of new loans for the fourth quarter of 2017 demonstrated a 7 per cent rise on figures for the same period of 2016, with loan values climbing 9 per cent - a truly impressive reversal of fortune.
Given this context of shifting market conditions and fundamental industry upheaval, it's likely that many of the indiscretions identified within the FCA letter are attributable to the short period of time with which lenders have been expected to implement the new MCOB requirements, as well as a resulting failure to adequately design and oversee the multitude of overlapping strands at this time of great duress.
But that's no excuse as some lenders appear to have got it right with exactly the same challenges.
The FCA has already conceded that, where required, those firms which had been subject to a process of investigation have each taken subsequent steps to improve on their affordability assessments and many industry insiders, such as the FLA’s head of consumer finance, Fiona Hoyle, have insisted that lenders will be grateful for those insights, which will "help firms to fully embed" the new compliance regime.
Following the FCA review on mortgage advice it was clear that not everyone had the same interpretation, and the subsequent FCA report was hugely beneficial to show advisers there was a level playing field.
Similarly, the seconds lenders need to take this opportunity to reassess their businesses in light of this feedback and make changes if required.
Of course, many state they are already in good shape with experience from their established first charge divisions standing them in good stead.
The industry is on a sound financial footing and making great strides towards fulfilling regime requirements.
It has undergone a period of intense pressure and is now returning to pre-MCD levels of business.
It isn’t quite perfect yet, but it will be.
Steve Walker is managing director at Promise Specialist Lending