The APCC intends to respond to the FSA's CP following the Mortgage Market Review.  At this stage it is gathering responses from members and other interested parties.

MORTGAGE MARKET REVIEW
The mortgage market review – CP31/11 , issued on 19th December as an early Christmas present to the industry, is alleged to be the biggest consultation the FSA have published.

It is wide ranging and has significant potential impact to both lenders and intermediaries, not to mention customers who will be impacted by the proposed changes.

The APCC would like to respond to this CP and we are interested in hearing from members in this respect. We believe it is in our interests to do so and will help continue to raise our profile within the FSA.

To this extent we would appreciate responses to the following questions so we can determine the best way forward:

• Are you interested in providing feedback to the Consultation?
• If the FSA were willing to attend a meeting where we could facilitate a Q&A and provide some feedback to them would you wish to attend (probably London based)?
• If the FSA were not willing to attend would you be interested in attending an APCC session to discuss the impact and gather feedback towards our response?
• Do you want to provide the APCC with responses to any of the specific questions from the consultation but not attend a meeting? (see list of questions for completion)
• Is your interest in a) intermediaries b) lenders c) both?

We recognise that it is often difficult for a wide ranging body such as the APCC to get a consensus on every aspect but we do hope to be able to get consensus on a lot of points and can then provide a split view on the other parts. It does, however, take a great deal of time and effort to co-ordinate and draft up and the earlier we start the better.

Please send in your response to the APCC by 27th January.

We now have dates for events in 2012 so please put them in your diary, more details to follow in the New Year.

Dates for events in 2012 are below, more details will follow in the New Year.

2 February:  London - Business Risk Awareness Workshop
12 March:  London - Annual Forum
20 June:  Huddersfield - Northern Forum
19 September:  Huddersfield - Northern Forum
19 December:  Huddersfield - Northern Forum

The APCC has been working with the FSA and the ICAEW on providing guidance compliance consultants on S166 reports.

The APCC started a project back in late 2010 to prepare guidelines for consultants on the preparation of S166 reports.  The initial short form guidance covered report scoping, preparation of the fee quote, the report content, preparing the report opinion, discussing the report with the client and finally getting paid for the work.  This guidance was discussed in detail with the FSA and was near finalisation when structural change within the FSA meant that the role of the S166 report oversight team was moved to the PRA.  The PRA team had already engaged with the ICAEW to provide technical guidance to ICAEW members on producing S166 reports and the FSA then asked this to be extended to cover reports dealing with conduct risk.  As a result the APCC was invited to join the ICAEW working party for the technical guidance being produced.  Our input has made the technical guidance (which is still in draft form and not yet published) significantly more relevant to compliance consultants than it would otherwise have been. 

Once the ICAEW tehcnical guidance is published we will ensure it is available to all our members.

On 25 November the APCC held a Northern Forum in Huddersfield.  The main item for the forum was a presentation by the FSA on the Business Risk Awareness Workshops being held for every retail firm and the follow up process for these workshops.

Delegates from APCC member firms were invited to a free workshop and forum on 25 November in Huddersfield at which the main item was a presentation on the Business Risk Awareness Workshops being held for every retail firm and the follow up process for these workshops.  Nicholas Ross and Grahame Hinselwood from the FSA talked through the workshops and ran a live case study for delegates to comment on.  The presentation was very useful for both delegates and the FSA as feedback from delegates will enable the FSA to improve the case study and make it more relevant to the various different retail firm types.   Delegates at the event are now much clearer about the purpose of these workshops and the follow up actions the FSA will be taking with firms.

 
Since the early summer of 2011 the APCC has been working with the FSA to identify ONA issues and their solutions.

Consultants from APCC member firms have identified an extensive list of issues with the ONA reporting system and these have formed the basis of extensive correspondence with the FSA over how these issues should be addressed.  While it is clear that resource constraints within the FSA mean that there will be no large scale review and improvement of the ONA system in the near term nevertheless the exercise has been useful.  We will be publishing the list of issues and their workrounds shortly.

The APCC held an RDR and Platforms workshop on the afternoon of 19 October.  Rory Percival and Colin Wilcox from the FSA attended.  Rory Percival plays a leading role at FSA on the implementation of Retail Distribution Review, platform use by intermediaries and suitability of investment advice.  The purpose of the workshop was to discuss the more complex issues arising in these areas. 
This was an interactive workshop where delegates had the chance both before and during the event to raise issues and question with the FSA and to discuss them with their fellow consultants on what was and still is clearly a contentious area. 

The APCC held an RDR and Platforms workshop on the afternoon of 19 October in central London.  Rory Percival and Colin Wilcox from the FSA attended.  Rory Percival plays a leading role at FSA on the implementation of Retail Distribution Review, platform use by intermediaries and suitability of investment advice.  The purpose of the workshop was to discuss the more complex issues arising in these areas.  Delegates were asked to send in their issues so they can be raised with the FSA beforehand so they could come fully armed.  This was an interactive workshop giving delegates the chance both before and during the event to raise issues and question with the FSA and to discuss them with their fellow consultants on what is clearly a contentious area. 

A number of issues were not fully resolved during the workshop and these are being followed up with the FSA, delegates and APCC members will receive details of this correspondence as soon as it is completed.

STREAMED LIVE TO YOUR DESK
We were ablet to stream the workshop to consultant's desktop as a webinar so that they did not need to travel to London for the workshop.  Delegates who attend the workshop via the webinar were able to listen to the workshop, view the presentation and send in questions during the workshop via the Webex chat room facility.

TIMINGS AND LOCATION AND REGISTRATION DETAILS
The workshop was from 2 pm until 4 pm on 19 October and for those not using the webinar facility the workshop was at the offices of Resources Global, 117 Houndsditch, London EC3A 7BT. 

The workshop was free to delegates from member firms and £60 (£50 plus VAT) for delegates from non-members, whether delegates attended in person or via the webinar.   Delegates from non-member firms were only allowed to attend by webinar.