Consumer BTL Mortgages Current Position

Under the Mortgage Credit Directive, firms wishing to lend, administer, intermediate, arrange or provide advisory services in relation to Consumer BTL from 21 March 2016 will need to be registered by the FCA to do so. The FCA will start accepting applications later this summer.  HOWEVER, if you are already authorised the following will apply.

Firstly, you cannot do nothing. If you take no actiomn then a limitation will be  placed on your permissions that will prevent you from doing Consumer BTL mortgages. The FCA states,

As set out in legislation and CP15/3, the streamlined application process will only be available to those firms holding Part 4A permissions or interim permissions for consumer credit, and where a previous CBTL registration has not been revoked. This streamlined online process will only require firms to confirm that they wish to register (whether as a lender, administrator, adviser or arranger) and pay the relevant fee. When we begin accepting registrations, firms holding Part 4A permissions will be able to follow this process using a standalone online form through Connect. 


For clarity, if you are an existing mortgage broker you will hold part 4 permissions and so the streamlined applictaion process will apply to you. You wil lbe  able to make this application later this summer (their words not mine) through the Connect system and yes, it looks like you will have to pay a fee.


Please note: this applies to consumer BTL mortgages and not to commercial. However, I suspect that it will be  difficult in certain circumstances to prove that a BTL is not a CBTL and so I don't think that firms have much option but to register.

The good news however is that advising on BTLs and CBTLs will be taken out of Credit Broking under Consumer Credit Act  from 21st March 2016 and thus commercial BTLs will remain unregulated.

Action required of you: Watch this Blog and look out for FCA emails about this towards the ends of summer. Start saving for the fee!