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Is now the time to set up a healthcare REIT?
The emergence of specialist REITs focused on specific asset classes is good news for both investors and operators.
HCSTC regulator demands
The FCA has required that regulated entities:
- assess their lending activity to determine if their creditworthiness assessments are compliant
- inform the regulator if they are unable to meet financial commitments due to remediation costs
- take remedial action and consider proactive redress when deficiencies are found
- make appropriate provisions for any remediation required
- review their policies and procedures to ensure they comply with amended rules and guidance on assessing affordability in consumer credit (PS18/19).
Points of action:
- Refine strategy and governance: Consider the strategic objectives of the business and/or function, ensuring practices are responsible, proportionate and transparent, with a governance model to reflect and maintain these aspirations
- Reinforce accountability: Embed end-to-end accountability, ensuring product development and sales processes reflect regulatory requirements, risk exposures and customer vulnerabilities, while reinforcing and promoting responsible lending
- Proactively remediate: Instigate proactive redress and remediation exercises to address past shortcomings, thus demonstrating a commitment to good customer outcomes and reinforcing reputation through responsibility
- Evolve the business model: Draw on findings from proactive remediation exercises to evolve HCSTC business models and infrastructures, optimising controls, product development processes and complaints handling
- Actively shape the sector: Commit to playing a positive role in shaping the sector, contributing to regulatory evolution, countering disruptive influences and repairing reputational perceptions
To find out more on how we can assist with redress and remediation matters contact Alex Ellerton.
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