PS25/19: Key information

The FCA is replacing multiple returns with one unified return. Implications for mortgage advisers are:

• Mortgage advice complaints will now sit within a single cross‑sector classification improving comparability.
• Firms that previously completed DISP 1 Annex 1 only will now follow a more structured, permission‑based return.

The return dynamically shows only the sections relevant to a firm’s permissions. For mortgage intermediaries:

• Only mortgage-related product and issue categories will appear (alongside GI and pure protection categories where a firm holds insurance permissions). The FCA has provided a table on pages 33-40 of PS25/19 confirming the relevant product, service and complaint issue categories, enabling firms to collect data in a consistent format.
• This reduces misreporting and administrative burden.
• Firms must ensure permissions are up to date, as the return will rely on them.

Mortgage firms must report:

• All complaints where the customer is identified as vulnerable, regardless of relevance to the complaint.
• All complaints where the complaint relates to the firm’s failure to consider vulnerability (PS25/19, 1.6; 2.36–2.44). For example: A visually impaired customer receives a standard printed letter they cannot read, leading to a delay or detriment. Even if the underlying issue is administrative, this must be recorded as a vulnerability‑related complaint.

Firms should use the FCA’s four drivers of vulnerability:

• Health
• Life events
• Resilience
• Capability

Each legal entity must report individually

• Each authorised firm must report its own complaints.
• Complaints involving multiple entities must be reported by each entity involved.

This increases transparency and allows the FCA to identify where harm is concentrated.

AMI has confirmed with the FCA that Appointed Representatives (ARs) are not in scope of these changes, reporting remains the responsibility of the principal firm.

Nil returns can now be submitted upfront with a simplified process.

For small mortgage firms:

• Faster submission when no complaints arise.
• FCA still values nil returns for supervisory insight.

The FCA will publish firm‑level data only for firms with ≥500 complaints in a 6‑month period. This is a very high threshold and is unlikely to affect mortgage intermediaries, given typical complaint volumes in the sector.