Two new sets of research findings, by economic research consultancy Oxera and by economic and social research consultancy Policis, have been funded by the CML but are independent in their assessments.
They, along with the other evidence produced by the CML itself, should give the FSA pause for thought as they bring together a wide range of evidence that suggests there would be a range of negative, unintended outcomes from the implementation of the FSA’s policy and proposed rules as currently drafted.
Coogan said: "The FSA, like the industry, needs to have a clear steer from the Coalition Government about what type of regulatory structure is needed to support housing policy and deliver systemic stability in the mortgage market in the 21st Century.
"Before we go much further on the MMR, or the restructuring of regulatory bodies, we need Ministers to be clear about their intentions.
"Whether they want regulation to protect the vulnerable minority, or give an opportunity to the majority to achieve their aspirations.
"They can do both by allowing free access to the market to responsible borrowers, but establishing an effective safety net for the few who have difficulties due to changes in their lives. This is not the approach which the FSA has taken due to its limited focus on its conduct risk strategy.
"When we know what the Government wants the regulator to achieve, we and FSA officials will be in a better position to deliver the sustainable market for all participants which is flexible for consumers. These two outcomes reflect a shared vision by the FSA and lending industry.
"The CP proposals have blurred that vision to a point where neither outcome will be delivered by CP 10/16 as drafted. If you agree, write to the FSA, your local MP and relevant ministers."
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