Ensuring FCA Compliance in Lifetime Mortgage Sales


With the Financial Conduct Authority’s announcement that they will be intervening “robustly” following their findings that poor advice is being given in the Lifetime Mortgage market, it’s now urgent for lifetime mortgage providers and advisors to review their processes in order to ensure compliance. One key finding was that intermediaries were “incentivising sales potentially at the expense of quality advice and good customer outcomes”, which immediately falls foul of the FCA’s New Consumer Duty. Some industry insiders have expressed their lack of surprise at the findings.


A man in a blue jacket and lavender shirt sitting behind a desk. You can see only from his shoulders to his waist and his body is out of focus. He is holding his hand out towards you and the hand is in focus and is holding a toy house. The house is fancy, and white with pale blue and pale green accents.

So as a Lifetime Mortgage provider or advisor, what can you do?

Define your objectives

  • Advice needs to be personalised. Your borrowers’ income and expenditure obviously need to be taken into account, but also advice needs to be delivered in a way that is understandable by each individual – if you’re presenting written information, do they understand it? Do they comprehend any industry terms that you’re using? Are you actively gauging their understanding throughout?
  • Suitability needs to be evidenced– Why is a product being introduced/suggested? Why is this more suitable than the alternatives? These elements need to be completely clear so that the borrower understand not only the product that they’re being sold, but the reasons for that and the details of any alternatives so that they can make an informed choice of what is most suitable for their own needs and situation.
A view across a wooden desk from one end, with two laptops open on it and a notepad between them. You can see the arms of two people in business attrire, and their arms are resting on the desk. One is holding a yellow and black pencil over the notepad. The notepad had scribbled notes and diagrams on it. The impression is that they are conducting a business planning meeting.

Implement your Processes

Once you have clear objectives, it’s important to define the key processes that you will put in place to facilitate them. Making sure that these are systematised, so that all relevant staff (both those existing and those yet to come on board) will be following them from the outset is crucial.

Monitor Compliance

  • Regularly solicit customer feedback – It’s important to actively gauge satisfaction and understanding throughout the sales process, of course, but a universal, structured process by which this data is collected at the end of each sales process (whether or not it resulted in the customer taking out the finance) and evaluated is crucial in ensuring that the outcomes that you’re aiming for are being achieved, and any failings promptly identified.
  • Regularly solicit staff feedback – If there are pain points in the process – anything that advisors struggle to incorporate, or points at which they are finding that a clear customer understanding is not being achieved – it’s vitally important that you are getting this information promptly from those ‘on the ground’ so that you can review processes as needed to achieve and maintain the FCA’s required outcomes for your customers.
  • Objectively monitor processes – Even with regular customer feedback, you can find (due to the tendency for customers to feedback more when they’re either very happy or very annoyed) that elements are missed – particular advisors starting to be less consistent in following processes, for example, or particular parts of the process that miss the mark more than others. A well-planned specialist Compliance Mystery Shopping and Ongoing Monitoring Programme will promptly let you know which areas need your attention, and will automatically bring your organisation’s key stakeholders (team leaders, area managers, compliance team, etc.) into the resolution conversation.
A screenshot of a reporting dashboard for financial compliance monitoring. The graphs are blue and purple. The top graph is a line graph showing the trending overall scores for mystery shops on lifetime mortgage advisors. The second graph is a bar chart showing the section scores for compliance mystery shops on lifetime mortgage advisors. At the bottom of the screen a table titled 'Flashpoints' can be seen.


By taking this systematic approach to FCA compliance in your Lifetime Mortgage business, you will:

  • Increase customer loyalty by building a culture of customer trust and satisfaction.
  • Stay on the right side of the conduct regulator.
  • Improve and maintain your brand’s reputation!
A man and a woman sitting either side of the corner of a wooden desk with an open laptop, some printed sheets, and two coffee cupts on it. The man on the left has short, dark hair and a beard, and is wearing a light blue shirt and a blue striped tie. The woman on the right has long, dark brown hair and is wearing a shite shirt and a black blazer. They are both smiling broadly and are high fiving each other.

At Customerwise we work closely with lenders, brokers, and other specialists in the consumer finance space to create tailored 360 degree monitoring and feedback programmes to support FCA compliance. We’d be delighted for you to book in a discovery call with us to see how we could help your business. If you would like to know why you should call us, please watch this short video.


This was first posted on LinkedIn. You can view the original post here.

If you’d like to find out more about the services we offer for the finance sector, you can do that here. We’ve helped clients like you in improving their regulatory compliance, and we’d love to do the same for you.

Tamsin Palmer

Tamsin Palmer

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