Pre-Application Disclosures
The company uses the rules and guidance set out in MCOB 5 to ensure that all customers are provided with key information about the home finance transaction before they apply to us (the home finance provider). Such information is always disclosed in a consistent way to ensure and facilitate comparison between products of different providers.
It is our aim and intent to ensure that prior to the customer being able to apply for a home finance transaction, they are always supplied with information that makes clear: –
- The home finance transaction features, any linked deposits, any linked borrowing and any tied products (in relation to a regulated mortgage contract)
- The price that the customer will be required to pay under that home finance transaction, to enable the customer to make a well-informed purchasing decision
During the pre-application phase for any home finance transaction, the company always discloses and makes it clear to the customer that: –
- Where an illustration has been provided to a customer, we detail and explain the full importance of reading the illustration and understanding it
- That all illustrations are provided in a durable medium
Whenever we provide a customer with information specific to the amount that the customer wants to borrow on a particular regulated mortgage contract following an assessment of the customer’s needs and circumstances, we always clearly and prominently provide the following information: –
- Whether there are any limitations in the range of products that we will offer to the customer, and if so what those limitations are
- That the customer has the right to request an illustration for any regulated mortgage contract which we are able to offer the customer
The only exception we place on providing the above information is where we have previously (and have recorded as such), the customer already having been given the same information previously within the last ten business days.
The company uses an Illustration Record Log to record each illustration that is issued by us to a customer in accordance with MCOB 5.5.1 R where the customer applies for that particular regulated mortgage contract. Such records are retained for 1 year after the application date. The record includes: –
- The date on which the illustration was provided to the customer
- The date of the application made by the customer
- The application account number
- The Customer name(s)
- The person who provided the illustration
- Details of the medium through which the illustration was provided
6.11.4 Illustration Record Log (Excel)
Insert location/hyperlink to external location of this document]
[We have included a template for this document in 02_Manual_Supporting_Docs]
6.11.5 Illustration Document
A copy of the standard Illustration document used by the company can be found in [section XXX] of this manual (use the FCA’s template here if needed – Use MCOB 5 for the requirements of completing the Illustration). It is regularly reviewed and assessed to ensure its continued compliance and has been authorised for use by the Compliance Officer in accordance with the below requirements: –
- It contains the material set out in MCOB 5 Annex 1 in the order and using the numbered section headings, sub-headings and prescribed text in MCOB 5 Annex 1
- It follows the layout of the template in MCOB 5 Annex 1 with:
a. prominent use of the keyfacts logo followed by the text ‘about this mortgage’
b. each section clearly separated
c. all the amounts to be paid in Sections 5, 6, 8 and 9 in columns that make the amounts of the payments clear
d. no section is split across different pages, except where it is impractical not to do so - It uses font sizes and typefaces consistently throughout the illustration which are sufficiently legible so that the illustration can be read easily by a typical customer
- It ensures that the information within each section is clearly laid out and is fully legible
- It includes prominent headings with the numbered section headings clearly differentiated in some way from the other text in the illustration
- We have replaced ‘[name of mortgage lender]’ with the name of the mortgage lender providing the regulated mortgage contract
- It describes any early repayment charge as an ‘early repayment charge’ and not use any other expression to describe such charges
- It describes any higher lending charge as a ‘higher lending charge’ and not use any other expression to describe such charges.