
To advise or not to advise?
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Advise or not to advise?
That seems to have been a key question for mortgage brokers in 2016 deciding whether or not to advise on second charge loans themselves or to refer clients to a master broker instead.
Worryingly however there seems to be a third option in play and that is ‘doing a bit of both’. Ok I’m being facetious, I’m sure brokers don’t knowingly choose this approach but there are certainly a number of mortgage brokers out there who risk blurring the lines in a couple of ways and consequently getting it wrong.
Dipping in and out of seconds on an ad hoc basis is certainly going on. By this I mean offering a second charge on an inconsistent basis – maybe as an after thought. Brokers should be clear on their scope of services and have processes and documentation to make it obvious to their clients. Options could include considering a second charge every time or simply opting out of seconds altogether. Either way every client should be offered the same range of services and the business must decide what those services are and have a process to deliver them consistently. Offering a second charge only to those who ask for it, or most obviously need it, falls well short of being consistent.
Key Criteria & Application Guidance
Secondly in a referral scenario some brokers have difficulty in relinquishing the advice and can try to over rule the chosen loan. I understand this and it demonstrates the broker’s commitment to their client. However, if the advice is being taken on by a loan specialist, beware getting involved or overly influencing the chosen product.
The loan broker must give advice in accordance with its fact find and will be on the hook for the suitability. By all means provide background to the case to help them identify all the key points but ultimately they must give the advice. If you disagree it suggests that their facts differ from yours which points to mixed messages from the client or a poor fact find somewhere along the way. Between the parties get the facts right and the chances are you will come to the same conclusion.
Be clear in your scope, say what you do and do what you say. Lack of clarity or blurring the lines can only lead to problems later.
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Whole-of-Market Guidance for Second Charge Advice Rules
Securing competitive terms on second charge advice rules requires expert underwriting knowledge. In addition, our specialist broker team works directly with over 90 specialist lenders across the UK.
Consequently, reviewing your second charge advice rules options with an FCA-authorised specialist credit broker ensures whole-of-market access while avoiding unnecessary fees and delays.
Specialist Underwriting & Whole-of-Market Access
Because specialist lending facilities require bespoke underwriting, comparing lenders across the UK is essential. Explore our complete guide to Specialist Lending Desk to understand how different lending criteria apply to your requirements.
Promise Money is an independent credit broker authorised and regulated by the Financial Conduct Authority (FRN 681423). Our experienced team reviews your specific circumstances to secure optimal terms across 90+ UK lenders.
Key Takeaways: Second Charge Advice Rules Checklist
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Learn about our 35 year story >

Steve Walker
Managing Director – 40 years of experience
Founding chairman of the Corporation of Finance Brokers. Specialist in UK residential mortgages, secured loans, and regulated bridging.

Simon Carr
Commercial Director – Proptech
Specialist in complex mortgages, commercial underwriting, and developer finance. Architect of Promise Money’s automated lending tools.

