Newsletter Compliance Update The Compliance and Training & Competence function are receiving more requests to review re broke cases where there is an ERC. We therefore think that it is timely to remind advisers the process that is expected for each case. Rebroke approvals fall into three broad categories:i. ii. iii.
ERC is less than £5,000 the adviser can proceed ERC is greater than £5,000 but less than £10,000, the adviser needs to discuss the case with the Compliance Function - Please contact Rob or David. Do not contact Jane. ERC is greater than £10,000, the adviser will need formal approval from the Compliance Function to proceed.
For all cases falling within ii and iii, advisers must provide a full analysis of the loans and costs using the re broke calculator available on CRM. Where the client has a number of different loans (drawdowns) with different interest rates, it will be acceptable to provide the analysis based upon an average interest rate where applicable. Advisers will need to send this information along with a full synopsis of the case, including but not limited to why the client needs to re broke, why they need any additional funds etc and the clients age. For any cases that potentially involves moving an LMD case to Whole of Market, the case will need authorisation from Rob Brennan. Rob will need the case code along with a full explanation as to why the case needs to go Whole of Market. Therefore in addition to the information listed above, advisers should complete the Flex Tool and submit this along with an indicative interest rate available from the market. Please remember that this should be based upon the clients actual circumstances rather than the lowest rate available. We will be creating a full process for advisers to follow and make this available on CRM in the first appointment documents. For all cases approved, advisers will be issued with a short approval form which they will need to upload onto CRM.
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