As a regulatory body, we’re poring over our Constitution to make sure we don’t rub up the wrong way against the 2014 Consumer Credit Act. But as a training and education body, we’re instructing, and inviting comment from, brokers around the UK who are unsure how the CCA changes will affect them.
There’s not just a single new rule to follow, but a whole bunch of new rules and a similarly large number of possible reactions that we and our lenders can take. It’s the NACFB’s job to encourage our lenders to behave cohesively – and with ninety-five patrons actively lending, that’s not an easy task. We have got a few months before 1st April, but I’ve a feeling they’re going to tick by pretty fast.
We asked our lenders: “What categories within the CCL do your introducers need to hold as a minimum?” Our asset finance lenders spoke with one voice. Commercial mortgage lenders were much less in agreement with one another. And therefore, the Association may need to treat our asset members differently from our other members (who are largely working in commercial property).
Those brokers making the sideways move from regulated to non regulated property business will probably go on doing so, but if life looks somehow easier for the asset finance brokers – because we can offer a clearer set of guidelines and a less complex route to funding – then I can imagine that attracting some of the new guard.
As we move further toward the role of adviser and consultant, we’ll be keeping a close eye on what our members represent – who is leaving the pitch, and who’s limbering up to take their place. But our message to prospective brokers who are looking to enter the market, remains a positive one. Huge numbers of small businesses are growing and seeking funding. A revised CCA should be a small price to pay for the opportunities that compliance will open up.
