The trade body for the mortgage industry has written to the Chancellor of the Exchequer. In its letter to Alistair Darling, the Council of Mortgage Lenders (CML) outlines the range of steps that lenders are, apparently, taking to minimise problems borrowers may face in the wake of the credit crunch — and help limit the number of property repossessions. Its members have committed to four “significant specific measures”. These are, in the CML’s own words:

* To analyse their existing arrears management policies and implement any changes identified as a result of the industry guidance which we (the CML) are preparing. The guidance will be informed by the feedback we receive from the FSA (Financial Services Authority) on its thematic work on arrears management. We hope the industry guidance will in due course be confirmed by the FSA, but we are at a very early stage of this process.

* To provide consumer information to borrowers in arrears to help explain the arrears management process, to help borrowers understand what to do and expect, and to set out how their lender will treat them fairly.

* To introduce an appropriately worded pre-action protocol for mortgage cases for use before court proceedings.

* To ensure they have a strategy for contacting borrowers coming out of initial deals, such as two or three year fixed rate periods, to inform them in good time of their new payment and encourage them to make contact if a financial problem is likely to arise.

Despite all the words, there appears to be little substance to these “significant” measures.

As the CML maintains, the number of mortgage arrears cases and repossessions are likely to remain low — and certainly far below the level reached in the housing market crash of the 1990s. Huge increases in house prices in the past few years have meant that, for many, the average loan-to-value is likely to remain low, meaning comparatively few borrowers are facing the prospect of negative equity. Indeed, HSBC unveiled data last month that showed the average mortgage from a stampede of new business represented only 56 percent of the value of the property it was secured against.

That said, some borrowers ARE suffering at the hands of lenders who continue to try to protect their margins and limit bad debts. Across the industry, the maximum amount people can borrow in relation to their property value has plummeted, cheap deals have been replaced with more expensive ones, rules of who can borrow what have been tightened considerably and fees have doubled. The housing market continues to be choked by the lack of mortgage availability, particularly for first-time buyers and those with little in the way of deposit.

At the same time, a two-tier system is emerging whereby the best deals are only available to homeowners dealing directly with lenders — not through intermediaries that generally charge lenders commission. That is effectively making bypassing independent brokers, who help consumers search the entire market for the best deal for their circumstances, uneconomical. Surely, that can’t be right?