Compliance and Initial Disclosure Requirements | Mortgage and Home Finance Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

Disclosures

As a provider of mortgage and home finance products, the company has a legal and regulatory duty to ensure that customers are provided with key and specific information at varying intervals throughout the promotion, application, term and after sale periods. This information is described by the FCA as ‘Disclosure Information’ and is intended to be consistent across all mortgage and home finance providers to ensure consistency and clarity.

[You can either insert your Illustration & ESIS document here or reference the external location of the document. Your Key Features (ESIS) document MUST include all the below disclosures if they are applicable to the services that you offer]

Where it is a regulatory requirement to disclose information to a customer in a durable medium, defines this as the company paper or any instrument which enables the recipient to store information addressed personally to him in a way accessible for future reference for a period of time adequate for the purposes of the information and which allows the unchanged reproduction of the information stored.

Additional disclosures are required for firms who must comply with the MCOB regulations. These additional disclosures complied with in full by the company and are covered below.

6.11.1 Disclosure Compliance

[ADD/DELETE AS APPLICABLE]

For all information disclosures that are a regulatory requirement by the company, we ensure that such information is being disclosed as part of our service and monitor ongoing compliance with information disclosures using the below procedures and methods: –

• Scripts with the disclosure details written down for face to face and telephone sales/advice
• SMS and Email have the written disclosure requirements embedded into the top of the message content and all outgoing messages are reviewed for compliance during our routine monitoring schedules
• All information disclosures are given to customers on a durable medium and in a timely manner
• Live and recorded sales and advice telephone calls are audited using compliance procedures and scripts for adherence to the MCOB 4.4 disclosure rules
• Ongoing training on the disclosure requirements and exact wording is provided to all staff and assessments are used to ensure knowledge and understanding in this area
• This compliance manual is made available to all staff as a means of and information resource, support and training aid
• Where telephone and face to face disclosures have been made verbally, we follow up by providing the information in writing also
• We disclose all relevant customer information via our website in an easy to see, navigate and understand format
• Prompts and screen pop-ups are used during contactless sales, such as the internet and via the website, to ensure that the disclosure information has been read and seen – this also requires a tick box option that the customer must interact with in order to proceed to the next stage
• Procedures are in place for all disclosure requirements which enable us to monitor and audit the staff’s compliance against standardised and tested procedures

6.11.2 Initial Disclosure Requirements

Please refer to the Advising & Selling Policy for our Initial Disclosure objectives and procedures.