Who is responsible for the accuracy of the key facts illustration (KFI)?
This depends on who produces the KFI and who gives it to the consumer: • the lender is responsible for the accuracy of a KFI which it produces and gives to the consumer; • a lender is responsible for the accuracy of a KFI which it produces and provides to an intermediary so the intermediary can give it to the consumer; • the intermediary is responsible for the accuracy of a KFI which it obtains from a third party sourcing provider (or makes up itself); and • sourcing system providers are not subject to our rules (as they are not usually carrying out a regulated activity) and so cannot be held responsible for any failure to comply with our rules. To provide accurate KFIs, a sourcing system provider may ask lenders to guarantee the accuracy of its data and lenders may decide this is more effective than the alternative of providing KFIs direct to intermediaries. We understand the industry is pushing for more integration between lender and sourcing systems and this may lead to integrated i
