AMI also argues that mortgage intermediaries play a vital role in helping consumers decide what they can afford, which mortgage is appropriate, and in this they should be supported by the industry and the regulator.
The comments are made in "Better Regulation For The Mortgage Market", the second paper to be released by AMI in the run up to the publication of FSA’s Mortgage Market Review, expected in mid October.
AMI Director Robert Sinclair said: "The regulatory structure needs to balance the need to protect consumers from unaffordable debt with their desire to buy a home of their own.
"Product regulation risks strangling innovation and competition. Prescriptive Loan-to-Value controls will prevent vulnerable consumers from moving to more affordable mortgage deals when they seek to remortgage. And Loan-to-Income restrictions will penalise the careful consumer not the frivolous borrower. There are sufficient existing regulatory tools in place to deal with such market issues. And niche products such as self-certification, remain appropriate for some borrowers and should not be completely driven out of the market.
"We are concerned that the high-profile failures in other countries, sectors, and of some business models, will force FSA to act. It is essential that regulatory interventions are both well timed and reflect a full understanding of their long-term impact on the market. Few things undermine market confidence faster than regulatory change driven by the winds of political expediency. We recommend that regulatory policy maintains its previous course and direction."
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