The Association of Mortgage Intermediaries (AMI) has responded to the FCA consultation on a new directory which will continue to show Appointed Representatives after the Senior Managers & Certification Regime has been extended.

This meets the requirements set out under the Mortgage Credit Directive.

AMI supports the addition of mortgage advisers to this list to improve transparency for firms and consumers.

However, the trade body has identified a lack of co-ordination between related consultations and the duplication of remit. The Work and Pensions Select Committee asked the FCA to improve its register, specifically to ensure that consumers could check if a firm or individual has had their permissions restricted or suspended. AMI says that the FCA is however proposing to go further than these recommendations by creating a tool for consumers to find advisers even though this facility is already provided by the Money Advice Service (MAS).

Robert Sinclair, chief executive of AMI, said: “We are concerned that the FCA appears to be working in silos both internally and distinct from organisations it’s supposed to be collaborating with. There is a risk of a waste of resources.

“AMI perceives that there is a regulatory view that MAS is a third party on par with a commercial firm, whereas MAS is a statutory body funded by industry in the same way as the FCA.  The memorandum of understanding between MAS and the FCA commits to ‘minimise inconsistency and duplication and to promote coordination’ by ‘working together on information aimed at consumers’. We would have expected the FCA to consider MAS’s existing retirement adviser directory rather than the duplication set out in these proposals. The FCA should have also consulted more widely before adding this function to the current register.

“These proposals directly cut across the Mortgages Market Study work on broker choice published in May 2018, and we are asking the competition team to reconsider their plans given this directory consultation published in July. The new directory will show a list of all advisers, including mortgage advisers, and the information that will be displayed addresses most of the issues raised in the market study.

“Firms shouldn’t be asked to pay for two pieces of similar work running side by side. Our view is that the new directory should stop at the point of outlining firms’ permissions and any search facility to find an appropriate adviser should sit within the adviser directory held by MAS and its successor.”