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Sales and Advice

Disclosure timings and TCF

FSA research has revealed that a significant number of mortgage firms don’t issue disclosure documents to customers in accordance with the MCOB required timings, and in a few cases fail to issue them at all.  This impacts on TCF because a customer may feel pressured to proceed with a mortgage when they don’t understand the full facts, or may not have sufficient time to consider the information they receive.

The table below may offer a useful training aide in support of TCF.

Disclosure document

Timing

TCF risk if late or not provided

IDD
‘Keyfacts about our mortgage service’

At initial point of contact, or within five days (by post or email) if initial contact was by telephone.

Customer won’t have the time (or else opportunity) to assess whether they are happy with type and cost of service and/or range of products available.

Customer won’t be able to compare your service with others on offer.

KFI
‘Key facts illustration’

When making a recommendation. To be provided before the customer applies for the mortgage; not at the same time.

If the customer asks for a personalised illustration (advised or non-advised sales). To be sent within five days of the request if a telephone sale.

The customer won’t have the time (or opportunity) to compare the product with others on offer.

Customer risks being pressured into taking out the mortgage without proper time to assess the key features, risks and costs.

If KFI not provided and the mortgage doesn’t proceed the customer won’t understand what fees are and aren’t refundable.

See the Client contact log for a simple example of how you can record when the IDD and KFI are passed on.

 

  Download disclosure timings table


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