Pepper Money (UK) Conveyancing Panel Information

In order to be on the Pepper Money (UK) conveyancing panel solicitors have to complete an application form and agree Terms and Conditions. A sample of 5 conditions that we see amongst many lenders Terms (but not necessarily Pepper Money (UK)) are as follows:

• To notify us in writing of any change in your details as held on our records for example, change of address, telephone number, document exchange number email address. Notification must be given to us at least 10 days before the change will be effective.
• To forward the title deeds and documents to another solicitor/conveyancer within 24 hours of an instruction from us requiring you to do so. On forwarding the deeds as instructed you will confirm to us that you have done so. Upon receipt of your confirmation, we will release you from all undertakings relating to your holding the title deeds.
• You have the consent of all borrowers to apply for the deeds, before making any request for deeds. We will accept your request for deeds on the understanding that you have obtained such consent. If this is not the case then you should advise our Deeds Services Department in writing when you make your request
• If you are a sole practitioner, to arrange for appropriate locum cover from our panel where necessary. Your locum must be a member of the Conveyancing panel.
• To quote on all communications with us relating to deeds/registration issues, whether by telephone or in writing, the panel number that we provide for each practising address and the mortgage account or application number for the mortgage concerned.

What you should do largely depends on the reason that your firm has been removed off the Pepper Money (UK) conveyancing panel. The top 3 reasons are as follows:

1. lack of transactions
2. the lawyer is a sole practitioner
3. as part of the HSBC panel reduction.

In these three circumstances it is unlikely that you would expected to take any action. Disclosure and other compliance considerations are more likely to be relevant if the reason for removal is due to breaches of lender requirements or allegations of fraud or negligence. Whether the reasoning should trigger a disclosable 'material' breach will depend on the firm and the circumstances around possible failures to comply with the SRA Authorisation Rules, and the SRA will judge each case on its own merits. Factors such as the detriment or risk of detriment to clients, the scale of the issue and overall impact on the firm will need to be considered in deciding whether a failure is 'material'. As the compliance officer you will need systems to identify patterns of breaches. Even if you don't consider there to be regulatory implications the firms COFA should give some thought to whether she/he needs to take any action as result of being removed from the Pepper Money (UK) conveyancing panel.

With mortgage companies and conveyancing firms working so closely with one another it is surprising that there has not been much call for the introduction of a bit of transparency regarding not just the figures for the Pepper Money (UK) conveyancing panel but for all bank panel listings

CQS membership gives no guarantee to lender panel acceptance. Nevertheless the CML have indicated that it is likely to become a prerequisite for firms wishing to remain on their panels. Some mortgage companies now use CQS as the starting point for Panel membership as is the case with HSBC.

You would be advised to get in touch with Pepper Money (UK) to obtain standard documents. The CML Handbook contains an explicit question for lenders to establish who to contact to obtain standard documents. Pepper Money (UK) in their Part 2’s state: Don’t forget to disclose your Pepper Money (UK) solicitors panel number.