Shaping the future: AMI responds to FCA mortgage discussion paper

AMI has now submitted our response to the FCA's Mortgage Discussion Paper; read our key messages to the FCA and read our response in full...

Advice isn’t optional, it’s the mortgage market’s future

AMI Chief Executive Stephanie Charman discusses AMI's response to the FCA's latest discussion paper and the value of advice for Mortgage Strategy magazine...

Your August ’25 update from AMI Chief Executive Stephanie Charman

AMI Chief Executive Stephanie Charman gives an update on what the team have been working on this month, and upcoming consultation deadlines...

Your August 2025 industry update

AMI's August 2025 update; what's new across the mortgage industry this month, including regulatory updates and industry initiatives...

Mortgage Sector in Focus; Stacy Penn writes for Moneyfacts

AMI Head of Policy Stacy Penn on how the UK mortgage market is evolving through regulatory reforms, tech advances and changing consumer expectations...
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Shaping the future: AMI responds to FCA mortgage discussion paper

AMI has now submitted our response to the FCA's Mortgage Discussion Paper; read our key messages to the FCA and read our response in full...

Advice isn’t optional, it’s the mortgage market’s future

AMI Chief Executive Stephanie Charman discusses AMI's response to the FCA's latest discussion paper and the value of advice for Mortgage Strategy magazine...

Your August ’25 update from AMI Chief Executive Stephanie Charman

AMI Chief Executive Stephanie Charman gives an update on what the team have been working on this month, and upcoming consultation deadlines...

Your August 2025 industry update

AMI's August 2025 update; what's new across the mortgage industry this month, including regulatory updates and industry initiatives...

Mortgage Sector in Focus; Stacy Penn writes for Moneyfacts

AMI Head of Policy Stacy Penn on how the UK mortgage market is evolving through regulatory reforms, tech advances and changing consumer expectations...

A time to stand still & reflect: What the MRR means for protection

Head of Policy Stacy Penn writes about the Mortgage Rule Review, in the latest issue of IRESS Industry Voice Magazine

“Everything changes and nothing stands still”. A quote attributed to the Greek philosopher Heraclitus, the push for change is everywhere. From a government driving a growth agenda, aiming to boost homeownership, to a regulator looking to simplify and streamline regulation making it easier for firms and consumers to do business.

Throughout May AMI’s attention has been on the FCA’s ‘Mortgage Rule Review’ consultation. On the face of it, the premise of making the mortgage process quicker and easier for consumers is a positive change. However, it goes wider and deeper than this.

The interaction trigger

An area with significant ramifications is the proposal to remove the advice ‘interaction’ trigger. The trigger requires firms interacting with a consumer in a new mortgage sale to provide advice and was introduced as part of the Mortgage Market Review (MMR) over 10 years ago. Fast forward to today, we have a market where 97% of mortgages are advised, with around 90% of mortgages transacted via intermediaries. The FCA believes the advised figure of 97% is too high and wants more consumers to have the choice to go execution only without being channelled into advice. It is difficult to comprehend how receiving advice is seen as a negative outcome of previous regulatory change that was put in place to protect consumers.

The current proposals undermine the important role of advisers and risk consumers making an uninformed decision on what is likely the biggest financial transaction of their lives. There is a chance that loyalty penalties seen in the GI market – an area the FCA has attempted to address through regulation – becomes prevalent in the mortgage market. Customers going through an execution only route with their existing lender may believe they are getting the best deal and worse ongoingly stay with that lender, never once reviewing the wider market and other – potentially better – options available to them.

Encouraging a shift to increased execution-only sales fails to recognise that the role of an adviser extends far beyond the mortgage transaction itself. Advisers play a crucial role in protecting the customer and ensuring a holistic conversation about the role of different protection products.

The value of advice

A customer choosing to go execution only on their mortgage may instil false confidence on protection, such as potentially foregoing advice and obtaining protection online or direct based on their belief of the right product and not what meets their needs. Furthermore, we know from AMI Viewpoint research that a house purchase is the main trigger for consumers buying protection, yet the FCA proposals risk creating a disconnect in the customer journey that will only widen the protection gap – an area of focus within the FCA’s own pure protection market study.

It is important for industry to continue conversations on the proposals, to help deliver meaningful change. There is a risk that the protection industry is focussed on the pure protection market study, whilst overlooking a more imminent challenge. Change is to be embraced but not to the detriment of consumers. In AMI’s view, innovation should enhance advice – not replace it. Change helps keep the world moving forward but standing still to reflect on the why and how is an important part of the process.

© 2025 Association of Mortgage Intermediaries Limited.

AMI is the trading name of The Association of Mortgage Intermediaries Limited which is a company limited by guarantee, registered in England and Wales under the Companies Acts with number 7982341. Our registered address is Celixir House, Stratford Business & Technology Park, Innovation Way, Banbury Road, Stratford-upon-Avon, Warwickshire, CV37 7GZ.

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