IDD content checklist

General

• FSA prescribed wording is used in each section – no ‘explanatory’ text, signature boxes, risk warnings etc are added anywhere in the IDD
• if you’re using the FSA IDD template document, optional information under MCOB 4 which isn’t relevant to your firm has been removed
• square brackets around optional statements from FSA IDD template document have been removed

Title, heading and branding

• the word ‘mortgage’ is included in the IDD heading, ie ‘Keyfacts about our mortgage services’ (unless it’s a CIDD)
• you company’s branding doesn’t diminish the Keyfacts logo
• your head office or place of business address is stated
• the official version of the Keyfacts brand is used
• the Keyfacts logo and words ‘about our mortgage services’ are positioned next to each other

Section 2: ‘Whose mortgages do we offer?’

• includes all three scopes of service, with the service your firm provides indicated in the tick box
• uses the term ‘We’ and not your firm’s name for each statement
• the extra sentence ‘Ask us for a list of lenders we offer mortgages from’ is omitted if you don’t provide from a limited panel of lenders, or if you include the list of lenders at this point on the document

Section 3: ‘Which service will we provide you with?’

• includes both options with the relevant box ticked, not just the option that applies to you

Section 4: ‘What will you have to pay us for this mortgage?’

• if a fee is charged, both the amount and when it is payable is included
• if you don’t know the fee (eg because it depends on the loan size), a representative example is shown - not the term ‘up to £XXX’
• if your firm will get a commission from the lender this is stated in plain language
• if no fee is charged there are still two boxes in Section 4 as follows - ‘No fee’ (ticked) and ‘A fee’ (not ticked)
• if further payment options apply, extra statements and ticked boxes are included to account for these
• if your firm is independent this section includes a ‘fee-only’ payment option

Section 5: ‘Refund of fees’

• if arrangements for partial refunds are available these are disclosed in addition to the prescribed wording
• this section is omitted and the subsequent sections renumbered if it’s not relevant because there is no fee, or a fee is only payable if the mortgage completes (optional – but will help TCF to leave it out if it’s irrelevant)

Section 6: ‘Who regulates us?’

• (renumbered to ‘Section 5’ if the section above is left out)
• gives a brief plain English description of your permitted mortgage activities, eg ‘advising and arranging mortgages’; ie doesn’t add undue length to the IDD document
• if you operate under a trading name, includes both your trading name and your name as it appears in the FSA Register

Section 7: ‘What to do if you have a complaint’

• (renumbered to ‘Section 6’ if the section above Section 5 above is left out)
• only includes relevant contact information (addresses, phone numbers etc) and the prescribed sentence ‘If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsmen Service’ – doesn’t include any other non-prescribed statements about complaints

Section 8: ‘Are we covered by the Financial Services Compensation Scheme (FSCS)?’

• (renumbered to ‘Section 7’ if the section above Section 5 above is left out)
• the prescribed text is stated in full

CIDD – (mortgage element)

Title

• the word ‘mortgage’ is omitted from the IDD heading, which instead reads ‘Keyfacts about our services’

Sections 2, 3 and 4

• sections 2, 3 and 4 include a sub-heading ‘mortgages’ and the content of these sub-sections are in line with the checklist above

KFI – Third party sourced or your own (note: accuracy is your responsibility)

General

• uses the FSA’s prescribed wording and section numbering throughout

Section 8 ‘What fees must you pay?’

• clearly states who the various fees/charges are payable to, their basis and what are for
• gives the correct fee/s
• where relevant an indicative fee is given (eg conveyancing) and the fact that it could be higher is made clear

Section 13 ‘Using a mortgage intermediary’

• this section is included if you or any third party receives a fee, commission or incentive from the lender
• the lender’s name and the names of anyone who receive fees, commissions or incentives from the lender are all included (ie your firm and/or any third party)
• the amount of commission and other incentives is stated if this is over £250

Contact details

• your firm’s name, address or other contact details at provided at the end of the KFI

Lender’s KFI

• If you use a lender’s KFI and feel that it’s confusing, have you asked for an improved version and explanatory notes in the meantime?