With effect from 21st March next year some BTLs, consumer BTLs will become regulated. The FCA has indicated that it requires firms to register if they wish to operate in this market and have recently provided the following flow chart to assist :
The document is a bit small here but the link to it is on this page. However , to save time the following applies if you are already authorised for regulated mortgages.
If you already have Part IV permissions (and if you are a mortgage broker you will have) so if you think that you might need permission to sell CBTL mortgages then you will need to register this via a form on Connect ( and pay £100 at the time of application), That is more or less all you will have to do. This is the basis behind the Nationwide comment about registering for the right permission.
The question then comes down to whether you think you might sell CBTL mortgages. I think that it is highly likely that if you do BTLs at some point within the year you are going to be facing at least 1 CBTL, Besides, even if you think the applicant does not fall into the CBTL category it is going to be up to the lender to decide which path they choose and if you don't have the permission you could lose a case.
In a word, pay the £100 and register and then the matter is sorted for you whatever the FCA and the lenders throw at you. I haven't looked on Connect as I am not a user but I would imagine that the form is one there right now or will soon be. It was promised at the end of summer and I guess from the dismal rain we have had recently, that is about now.
In the next blog I'll explain a bit about what is and what is not CBTL as far as has been publicised recent;y.
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