To: Financial Conduct Authority (“the FCA”)

VOLUNTARY APPLICATION FOR IMPOSITION OF REQUIREMENT

The Mortgage Matters Partnership ("Mortgage Matters"), as an authorised person
with a permission granted under Part 4A of the Financial Services and Markets
Act 2000 ("the Act"), hereby applies to the FCA for the imposition of the
requirement set out in the Schedule below:

SCHEDULE

1. General

1.1
Mortgage Matters has agreed to conduct a customer contact and
redress programme on the terms set out in Section 3 below with
immediate effect to ensure the fair treatment of its customers who
took out Debt Consolidation Mortgages with it between 1 January 2007
and 7 July 2014.

2. Definitions

2.1
Terms referred to in this requirement:

a) ‘Customer Letter’ means the letter to be sent to every Debt
Consolidation Mortgage Customer as defined in paragraph 3.1
below;

b) ‘Debt Consolidation Mortgage’ means a regulated mortgage
contract where a main purpose is to consolidate existing debts;

c) ‘Debt Consolidation Mortgage Customer’ means a customer
who was, or according to Mortgage Matters’ records may have
been, advised by Mortgage Matters to enter into a Debt
Consolidation Mortgage during the Relevant Period;

d) ‘the Relevant Period’ means the period 1 January 2007 to 7 July
2014; and

e) ‘Third Party’ means the independent third party as defined in
paragraph 3.4 below.

3. Requirement

Customer contact

3.1
As soon as practicable after an appropriate methodology has been
prepared at the conclusion of Phase 1 below, Mortgage Matters is
required to conduct the customer contact and redress programme in
accordance with the methodology and in particular to send a letter in
the form and terms set out at the Annex to this Schedule (“Customer
Letter”) by first class post to every Debt Consolidation Mortgage
Customer. No amendment shall be made to required form and terms of
the Customer Letter without the prior consent of the FCA.

3.2
Mortgage Matters will identify each Debt Consolidation Mortgage
Customer using Mortgage Matters’ New Business Register.

3.3
Mortgage Matters will use all reasonable endeavours to find an up to
date address, or find another appropriate method of contact, for any
Debt Consolidation Mortgage Customer for whom it does not have a
full address or for whom it receives a returned letter that cannot be
delivered.

Complaints handling

3.4
Mortgage Matters is required to appoint an appropriately skilled
independent third party contractor (“Third Party”), whose identity (as
with any replacement) is to be agreed in advance with the FCA, to
conduct the customer contact and redress programme work on behalf
of Mortgage Matters as set out at paragraphs 3.6 to 3.15 below.

3.5
Mortgage Matters will instruct the Third Party to handle on its behalf, in
order to treat its customers fairly and in accordance with its regulatory
obligations, all complaints that it receives regarding Debt Consolidation
Mortgages as a result of this customer contact and redress
programme. The Third Party’s work will be split into two sequential
Phases:

a) Phase 1 – Development of methodology; and

b) Phase 2 – Assessing suitability, establishing detriment and
calculating redress.

Phase 1 – Development of methodology

3.6
The Third Party will design an appropriate methodology to meet the
firm’s regulatory obligations for:


a) assessing the suitability of Debt Consolidation Mortgage advice;

b) establishing any detriment resulting from Mortgage Matters’ Debt
Consolidation Mortgage advice;

c) calculating any redress due to individual Debt Consolidation
Mortgage Customers; and

d) delivering an appropriate and effective customer contact and
redress programme in accordance with the requirement set out in
this Schedule. For example, the Third Party should include in the
proposed methodology how further information is to be obtained
from any customers who complain and how it can be reasonably
satisfied that the customer contact exercise has been conducted
and completed properly.

3.7
The methodology will take into account in particular the FCA’s
Principles for Businesses and requirements for mortgage firms as set
out in the Mortgages and Home Finance: Conduct of Business
sourcebook (MCOB) at the applicable time during the Relevant Period.
Particular focus should be given to the following:

a) The suitability rules in MCOB 4.7A (previously MCOB 4.7).

b) The specific debt consolidation rules in MCOB 4.7A.15 (previously
MCOB 4.7.6).

3.8
Phase 2 will only commence once the FCA has confirmed in writing that
it is satisfied that the methodology produced by the Third Party as a
result of Phase 1 is appropriate.

Phase 2 – Assessing suitability, establishing detriment and calculating redress

3.9
Mortgage Matters will pass onto the Third Party any responses (written
or otherwise) it receives in response to the Customer Letter, which
shall be regarded as complaints under the Dispute resolution:
Complaints (DISP) section of the FCA’s Handbook. For any complaints
that do not relate to Debt Consolidation Mortgage advice, or that the
Third Party considers to have already been resolved adequately by
Mortgage Matters, the Third Party will pass the complaint back to
Mortgage Matters to be handled in the normal course. Otherwise all

customer contact in relation to the complaints will be conducted by the
Third Party.

3.10 Mortgage Matters will instruct the Third Party to handle, on a timely
basis, all complaints that Mortgage Matters receives regarding Debt
Consolidation Mortgages.

3.11 The execution of Phase 2 will take into account the FCA’s complaint
handling rules in DISP and all of Mortgage Matters’ other regulatory
obligations.

3.12 The Third Party will, for each complaint that Mortgage Matters receives
regarding Debt Consolidation Mortgages, apply the methodology
designed in Phase 1 to obtain further information from the customer as
necessary and to assess if the advice was suitable.

3.13 Where the Third Party considers the advice given was unsuitable, the
Third Party will further apply the methodology designed in Phase 1 to
assess
any
detriment
resulting
from
Mortgage
Matters’
Debt
Consolidation Mortgage advice and report to Mortgage Matters with its
view regarding the appropriate amount of redress payable to individual
Debt Consolidation Mortgage Customers. Mortgage Matters will have
an opportunity to make representations to the Third Party in respect of
each customer.

3.14 Mortgage Matters will instruct the Third Party to respond to each
complainant in accordance with the methodology to indicate the
outcome of the complaint and, where applicable, offer redress on its
behalf.

3.15 Phase 2 may only conclude with the FCA’s consent.

Redress


3.16 Mortgage Matters shall promptly pay the redress due to each Debt
Consolidation Mortgage Customer who accepts its offer of redress
made pursuant to the customer contact and redress programme. If its
offer of redress is rejected then Mortgage Matters must notify
complainants of their rights to refer their complaint to the Financial
Ombudsman Service in accordance with DISP in the usual way.

3.17 Mortgage Matters and the Third Party shall report to the FCA as the
FCA reasonably requires from time to time. The Third Party shall in any
event produce a report at least every two months to the FCA setting
out its view regarding the appropriate amount of redress payable to

individual Debt Consolidation Mortgage Customers, with supporting
rationale for each customer.

3.18 Mortgage Matters shall promptly inform the FCA in the event that any
material issues emerge during the course of the customer contact and
redress programme.

3.19 For the avoidance of doubt, this customer contact and redress
programme remains subject to the overall oversight, approval and
jurisdiction of the FCA through Mortgage Matters’ FCA Supervisors in
the usual way and the FCA reserves its power to seek to amend the
customer contact and redress programme as appropriate, or substitute
other arrangements in its place, if it considers it appropriate for the fair
treatment of consumers or to meet its obligations or objectives
generally.

3.20 Any variation from the requirement in this Schedule must be agreed in
advance with the FCA.

3.21 The FCA will publish this requirement on its website.


Signed:

…………………………………………………………………………………………………..

Mr Charles Kleimunt, for and on behalf of Mortgage Matters


…………………………………………………………………………………………………..

Mr Jeremy Kleimunt, for and on behalf of Mortgage Matters



ANNEX TO SCHEDULE – CUSTOMER LETTER (to be on Mortgage Matters’
headed letter)

This letter is important and requires your careful consideration.

If you took out a Debt Consolidation Mortgage this letter is relevant to
you.

[Customer name and address]

Dear [Customer name]

Your Debt Consolidation Mortgage arranged by The Mortgage Matters
Partnership

Ref: [Customer reference] Date of Mortgage recommendation: [Date]

•
We are writing to you as a customer who may have been affected by failings
in our Debt Consolidation Mortgages business between 1 January 2007 and 7
July 2014.

•
Please read this letter carefully. If you think you are affected, we have given
you information on the steps you may want to take in the section below on
’what you should do next’.

What this means for you

This means that if you took out a Debt Consolidation Mortgage, we may not
have fully considered the costs and implications for you of consolidating debts
into your mortgage and as a result may not have given you suitable advice. In
particular, we may not have taken appropriate account of the following:

1. If you were having difficulties making payments at the time, whether it would
have been more appropriate for you to have gone into a debt management or
insolvency arrangement with your creditors, instead of incorporating your
existing debts into a mortgage.

2. Whether it was appropriate for you to secure a previously unsecured loan;
and/or

3. The costs associated with increasing the period over which your consolidated
debt was to be repaid.

As a result, if you completed a Debt Consolidation Mortgage with us we are
offering to reassess the advice we gave to you and review your file.

What you should do next

If you think you may have been affected, you should write to The Mortgage
Matters Partnership at 8 Stockport Road, Altrincham, WA15 8ET or email [Email
address] as soon as possible.

You should state the reason you wish your advice to be reassessed, and also
provide your current home or email address and contact phone number.

We have appointed an independent consultant, [name], to handle and review all
complaints. Making a complaint will not negatively affect your mortgage in any
way.

We also remind you that it is important that you regularly consider whether your
mortgage is suitable for your individual needs and circumstances, which may
change over time.

We understand that you may want to be sure that this letter is genuine. If you
wish to check the details on the FCA’s website please go to this link:

https://register.fca.org.uk and search the register for our reference number:
306863.

Although The Mortgage Matters Partnership is no longer trading, we are still
authorised and regulated by the Financial Conduct Authority.

If you have any queries about this letter, please contact us on: [Telephone
number].

Yours sincerely

For and on behalf of The Mortgage Matters Partnership