The FCA has published Discussion Paper DP25/2, a wide-reaching and potentially transformative consultation aimed at reshaping the UK mortgage landscape. The paper presents a broad set of proposals focussed on supporting sustainable homeownership, futureproofing later life lending, enhancing flexibility and innovation, and reassessing risk appetite to remove unnecessary barriers to access.
This is a pivotal moment for mortgage intermediaries, and as advisers you are uniquely placed to provide real-world insight on how regulatory change could affect consumers.
Here at AMI, we are actively seeking member views, holding open discussions with the regulator, speaking with other trade bodies and relevant adviser groups to ensure our response reflects a broad range of perspectives.
Below we’ve provided a high-level summary of the key themes within each chapter of the Discussion Paper, as well as our initial over-arching views.
Regulatory and government focus on the mortgage market signifies the importance of our sector in supporting economic growth. We welcome the FCA’s statement in the Discussion Paper that ‘effective advice is key to ensuring consumers that need advice are informed, get suitable products and achieve good outcomes’.
However, we are concerned about the FCA’s direction of travel on the concept of ‘enhanced’ advice and will focus heavily on this as part of our formal response and wider discussions.
The discussion paper goes broader and deeper than previous FCA work, however it is important to recognise:
AMI is grateful to have early input into shaping FCA policy. It is important that the housing market ecosystem is considered in its entirety, rather than in isolated parts. Sustainable progress requires co-ordinated attention across all segments – including social housing, the private rental sector, first-time buyers and home ownership into later life.
Currently none of these segments are operating effectively. Increasing support for first-time buyers, without a corresponding uplift in housing supply, risks further distorting demand, inflating house prices, and ultimately undermining the benefits of product innovation and affordability reform. Whilst outside of the FCA’s remit, AMI’s response will ensure we raise both awareness and concern that consideration should be given to both the provision of housing (new build and existing), alongside amendments to policy frameworks. Without this, consideration and interventions in siloes risk unintended consequences.
As the FCA considers changes that could reshape how the mortgage sector and importantly how advice is delivered, it’s never been more important for us to champion the value of advice and the role advisers play.
Your insight is invaluable in helping us shape our response to the FCA and we are calling on our members to:
If you’re interested in contributing or want to join a wider discussion, please get in touch.
© 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.
