FSA has banned and publicly censured the two directors of a mortgage firm for breaches of APER. It found they did not:
- implement adequate systems and controls to ensure mortgage advice to customers was of a suitable standard;
- get the right customer information or ensure the firm gave suitable recommendations; and
- monitor adequately the firm’s sales of mortgage contracts and keep adequate management information.
One director also did not ensure his roles for direction and oversight of the firm were delegated effectively when he was away for a long time. FSA would have fined the directors if that would not have caused hardship, so gave a public censure instead of a fine. The firm lost its permission because of the ban on the directors, which meant it no longer met the Threshold Conditions.