The FSA revoked the approval of Roger Collins, a Durham-based director of a mortgage broker firm, preventing him from holding senior positions in the financial services industry for at least two years. Collins was the only director and approved person in his firm Thoroughgood Harrison and Davies. An FSA investigation uncovered a series of failings that placed 300 customers at risk of receiving unsuitable advice.
A number of client files were reviewed and it was apparent that inadequate affordability assessments were undertaken by the firm’s advisers. One client was recommended a mortgage contract which exceeded his net income and others were recommended potentially unaffordable mortgage contracts which extended into their retirement.
From the Final Notice:
“In summary, in breach of Statement of Principle 7, you [Collins] failed to take reasonable steps to implement adequate and appropriate systems of control for (a) monitoring the Firm’s sales process and ensuring that it consistently and accurately obtained, recorded and assessed key information necessary to ensure that the Firm gave suitable mortgage advice and made suitable recommendations to its customers; (b) ensuring that the Firm retained sufficient records to demonstrate why mortgage recommendations were suitable; (c) ensuring that the Firm communicated with its customers in a way that was clear, fair and not misleading; (d) ensuring proper and effective compliance monitoring; and (e) ensuring compliance with the FSA’s training and competency requirements.”