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Outsourcing MCOB Activities

Where we have outsourced any related activities to a third-party processor, we always ensure that any rule in MCOB which requires the third-party processor, when acting as such, to disclose its identity to a customer, is read in full and fully discloses the identity of the firm (or appointed representative, as appropriate) which takes responsibility for the acts and omissions of the third-party processor when carrying on the outsourced activities.

For full procedures and compliance objectives relating to outsourced compliance activities and tasks, please see the Outsourcing Section of this manual.

6.2 Business Loans & High Net Worth Mortgage Customers

The company complies with MCOB clause 1.2.9C, which states that a firm may not treat a customer as being a high net worth mortgage customer for the purposes of MCOB unless either: –

  1. It is aware, from evidence already in its possession as a result of a business relationship between it and the customer, that the customer satisfies the definition of high net worth mortgage customer

OR

  1. It has first obtained a written statement which:a) confirms that the customer satisfies the definition of high net worth mortgage customer
    b) specifies the period for which it is valid, which includes the time when the regulated mortgage contract is entered into; and
    c) is signed by a suitably qualified professional adviser of the customer who is not an associate of the firm or of the customer.

Prior to working with any customer in the capacity of a High Net Worth Mortgage Customer, the company obtains written confirmation that the customer meets one or more of the above criteria and retains this information on file for 6 years after the cessation of the firm-client relationship.