Mortgage Lender Panel Removal Volumes

The request was successful.

Dear The Financial Conduct Authority,

Please see FOI7302 for reference 19/5/2020 FOI by Alaster Stuart.

I request the following in Excel format, from 2018 to date. Please breakdown the entries into months or per quarter if preferred. The request will require data to be anonymised, to comply with Section 44 of FOIA. The questions are designed around the data collected in the FCA's Information from Lenders (IFL) form.

Please provide a number of intermediaries removed from each lender panel (anonymise lender identity required).

Please provide a number of intermediaries removed from lenders panels (in general) that were Appointed Representatives.

Please provide a number of intermediaries removed from lenders panels (in general) where a mortgage lender CONFIRMED they believe the intermediary was "complicit in the fraud".

Please provide a number of intermediaries removed from lenders panels (in general) where a mortgage lender indicated there were "5 or more cases that caused concern".

The first question will be required to be anonymised, please replace a lender name with a reference that will show correlation without specifically identifying the lender. Section 44 defines Confidential information as non-anonymised information involving a person’s business or other affairs, which the FCA received. This request is for anonymised data.

Yours faithfully,

Adam Hosker

Freedom of Information, The Financial Conduct Authority

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The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

3 Attachments

Our Ref: FOI8173

 

Dear Mr Hosker,

 

Freedom of Information: Right to know request

 

Thank you for your email of 24 March 2021, in which you asked for data
collected via the Information from Lenders (IFL) form.  Full details of
your request can be found in Annex A below.

Having reviewed your request, we estimate that responding to questions 3
and 4 for the full date range, would exceed the cost limit allowed under
FOIA and therefore the exemption S12 (cost of compliance exceeds
appropriate limit) applies. For more information on why this exemption
applies, please see Annex B below.

When we refuse a request because it exceeds the cost limit, it is our
policy to provide you with advice and assistance on how you can refine or
limit your request so that it is more likely to fall within the cost
limit.  In this instance, we could consider a refined request limited to
questions 1 and 2 for the full date range and questions 3 and 4 from April
2019 to March 2021.

Should you wish to proceed with a refined request as set out above, please
confirm this in writing and we will process it as a new request in line
with the provisions of FOIA.

Your right to complain under FOIA

 

If you are unhappy with this response, you have the right to request an
internal review.  To do so, please contact us within 40 working days of
the date of this response at [1][email address].

 

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner by phone or on
their website at:

Telephone: 0303 123 1113

Website: [2]www.ico.org.uk

Yours sincerely

 

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[3]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

[4]www.fca.org.uk

 

Follow us:

 

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Annex A

 

I request the following in Excel format, from 2018 to date. Please
breakdown the entries into months or per quarter if preferred. The request
will require data to be anonymised, to comply with Section 44 of FOIA. The
questions are designed around the data collected in the FCA's Information
from Lenders (IFL) form.

 

1.    Please provide a number of intermediaries removed from each lender
panel (anonymise lender identity required).

 

2.    Please provide a number of intermediaries removed from lenders
panels (in general) that were Appointed Representatives.

 

3.    Please provide a number of intermediaries removed from lenders
panels (in general) where a mortgage lender CONFIRMED they believe the
intermediary was "complicit in the fraud".

 

4.    Please provide a number of intermediaries removed from lenders
panels (in general) where a mortgage lender indicated there were "5 or
more cases that caused concern".

 

The first question will be required to be anonymised, please replace a
lender name with a reference that will show correlation without
specifically identifying the lender. Section 44 defines Confidential
information as non-anonymised information involving a person's business or
other affairs, which the FCA received. This request is for anonymised
data.

 

Annex B

•       Section 12 (Cost of compliance exceeds appropriate limit)

FOIA requires us to comply with a request, unless it would be too
expensive to do so, as estimated in line with the Freedom of Information
and Data Protection (Appropriate Limit and Fees) Regulations 2004. 

Under these regulations, the cost limit for the FCA is £450, i.e. 18 hours
at the rate of £25 per person hour.  The regulations allow us to take into
account, when estimating the cost of complying with a request, the time
spent determining whether we hold the information requested, locating and
retrieving it, and extracting the information from the relevant
document(s).

To establish all the information that falls within scope of your request
would exceed the cost limit.  This is because prior to April 2019 we did
not hold the information you have requested for questions 3 and 4 in a
readily extractable format.  Therefore, in order to verify those details
we would have to manually review over 250 records.

We do not divert our resources from our regulatory functions to meet
requests under FOIA above the cost limit.  While we know this may
disappoint you, we are sorry we cannot carry out an exercise to identify
the information you have requested.

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

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5. https://twitter.com/TheFCA
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Dear Freedom of Information,

RE: Excess Costs

These should be boolean database entries, derived from the FCA's Information from Lenders (IFL) form. If they are not digitised prior to a specific date (as such the cost rises greater than £450) please refine the request to that earliest date.

In any event please refine the date from 2018 to the largest timeframe plausible to meet these requests(s).

Yours sincerely,

Adam Hosker

Freedom of Information, The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Dear The Financial Conduct Authority,

A polite reminder this FOI request was submitted 62 days ago or 32 days since we clarified the request.

By law, public authorities must respond “promptly” to requests. In any case, the law states that they must respond within 20 working days.

I hope to receive a response at your earliest convenience.

Yours faithfully,

Adam Hosker

Freedom of Information, The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

5 Attachments

Our ref: FOI8269

 

 

Dear Mr Hosker,

 

Freedom of Information: Right to know request

 

Thank you for your email of 25 April 2021, in which you asked:

 

‘I request the following in Excel format, from 2018 to date. Please
breakdown the entries into months or per quarter if preferred. The request
will require data to be anonymised, to comply with Section 44 of FOIA. The
questions are designed around the data collected in the FCA's Information
from Lenders (IFL) form.

 

1.       Please provide a number of intermediaries removed from each
lender panel (anonymise lender identity required).

2.       Please provide a number of intermediaries removed from lenders
panels (in general) that were Appointed Representatives.

3.       Please provide a number of intermediaries removed from lenders
panels (in general) where a mortgage lender CONFIRMED they believe the
intermediary was "complicit in the fraud".

4.       Please provide a number of intermediaries removed from lenders
panels (in general) where a mortgage lender indicated there were "5 or
more cases that caused concern".

 

The first question will be required to be anonymised, please replace a
lender name with a reference that will show correlation without
specifically identifying the lender. Section 44 defines Confidential
information as non-anonymised information involving a person's business or
other affairs, which the FCA received. This request is for anonymised
data.

 

In any event please refine the date from 2018 to the largest timeframe
plausible to meet these requests(s).’

 

We have processed your email in line with the provisions of the Freedom of
Information Act 2000 (FOIA) and our response is below.

 

The requested information can be found in the attached tables 1 to 4. 
When reviewing the information, please note the following:

 

•        The information has been provided on a best endeavours basis as
we are reliant on firms providing the details, completing it accurately
and it being inputted into the system.

•        Table 1 (Q1) reflects total removals in the period – 640 and
table 2 the ARs – 204 of the 640. 

•        The data provided in tables 3 (Q3) and 4 (Q4) is from May 2019 to
March 2021 as this is the data we have available in an easily extractable
format.

•        The answer to questions 3 and 4 is a judgement that the lender
makes and is not a confirmed position – i.e. they may believe the adviser
was complicit but have not always been able to verify this.

•        We are advised of panel removals via the ‘Information from
Lenders’ process, which is voluntary and not all lenders provide this
information and only removals that meet certain criteria are notified to
us.

•        Submissions can relate to individual brokers and/or firms and in
the case of a firm removal there may be several advisers/brokers removed.

          If you are unhappy with this response, you have the right to
request an internal review.  To do so, please contact us within 40 working
days of the date of this response at
[email address].

         

Your right to complain under FOIA

 

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner by phone or on
their website at:

 

Telephone: 0303 123 1113

Website: [1]www.ico.org.uk

 

Yours sincerely

 

Information Disclosure Team

[2]cid:image001.png@01D5F6F8.E90FD970

 

12 Endeavour Square

London

E20 1JN

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.ico.org.uk/