Putting Customers First | Key Issues Facing The Building Society Sector Post MMR

Since the Mortgage Market Review (MMR) was finalised in October 2012, in common with banks and other lenders, many building societies have found timely implementation of the resulting change a significant challenge. Implementation of the MMR is set against a backdrop where some firms are struggling to evidence that they are treating mortgage customers fairly and meeting existing Mortgage Conduct of Business requirements. So what are the root causes of these challenges and what can societies do to address them?

Societies continue to experience difficulties in evidencing that they are lending responsibly, particularly when lending to riskier customer groups, such as those with lower affordability or variable income, or when offering 'non-standard' mortgages. Many have struggled to develop mortgage advice processes for contract variations and to ensure appropriate numbers of adequately skilled agents. When a customer experiences financial difficulty, some societies are unable to demonstrate they are consistently proactive, and in particular, how they anticipate and understand customer circumstances over the short, medium and long term, then identify and discuss appropriate options (such as a forbearance option, a combination of forbearance options or an exit strategy) to find the most suitable arrangement for the customer's circumstance.

The Financial Conduct Authority (FCA) has imposed greater reporting requirements on the industry in relation to Product Sales Data (PSD) and the Mortgage Lenders and Administrators Return (MLAR), with the aim of being able to demonstrate that societies are lending responsibly. It is therefore important that societies have in place robust processes to collect the additional data required, including data on affordability and performance through the life of a product to make such regulatory returns.

These issues have at their heart a number of common root causes. Legacy technology increases the requirement for highly manual customer processes, making delivery of consistently fair and compliant customer outcomes more difficult. These manual processes place a real emphasis on robust training and competence arrangements, but are often found wanting as they do not ensure agents have the quality or frequency of training required to develop and retain competency in key customer facing areas. This compounds issues associated with these firms' resourcing models which often mean that customer facing staff are not...