The second charge secured loans market is under a period of change and
has been since April 2014 when responsibility for the regulation of consumer
credit transferred to the FCA. But there's also an EU Directive due
to be implemented in 2016. In short, when a customer wants to remortgage
to raise additional funds, the intermediary/broker will need to demonstrate the
best outcome for the customer and not only look at a full remortgage on a first
charge basis, but compare with an appropriate secured second charge loan
allowing the customer to keep the existing mortgage. Although the
Directive is still a way off, the FCA principles already apply to firms and
individuals so best outcomes and best practice for borrowers are at the
forefront of any advice and recommendation.
In fairness, and depending on the reasons for the capital raising, there
are numerous examples of borrowers being better off with a secured loan rather
than moving their existing mortgage, especially if it's an interest only
mortgage. In addition, those who are self employed with minimal accounts,
have historic adverse credit or need a greater flexibility than that offered by
first charge mortgage lenders, may have no other option than to look at a
second charge on their property.
So be prepared moving forward, if you want to raise some additional
funds on your property, you will be presented with a standard remortgage first
charge illustration as well as a secured second charge alternative. With rates
now starting from below 5% on a second charge loan, this may not be a
bad thing.
At the beginning of October, as mentioned in some previous articles, the
Bank of England has enforced capping restrictions to lenders.
Funders will now only be allowed to lend up to 15% of their loan book at more
than 4.5 times income. No one knows the true effect this will have to
funds available in the market generally, only time will tell.
Finally, it is really good to see a new lender coming to market.
Fleet Mortgages, a new Buy to Let lender is set to launch in November.
The management team are no strangers to the market as many have been involved
in various lending guises previously and we certainly welcome a fresh outlook
and further funding in the market. I wish them every success.
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