The Intermediary – March 2026 - Flipbook - Page 70
L AT E R L I F E L E N D I N G
Opinion
From niche
to norm
T
his is the second article
in a three-part series
exploring how later life
lending is moving from
niche to norm, and how
regulatory focus will
continue to accelerate that change as
the year progresses.
In the first article, I set out why later
life lending can no longer be treated
as a niche. Now, the focus turns to the
Financial Conduct Authority (FCA).
Through 2026 and into 2027, the
focus is firmly on outcomes, not
labels. The FCA has been explicit that
more people are borrowing into later
life, that pension income is oen less
predictable than in the past, and that
housing wealth is likely to play a far
bigger role in later life.
The regulator’s emphasis on
beer front-end assessment of
older customers is central to this.
It wants advisers to spend more
time understanding how a client’s
circumstances are likely to change,
rather than simply confirming
whether they fit within a set of
criteria today. That includes looking
at retirement plans, expected income
changes, and the role property wealth
may play over time.
The FCA has acknowledged
the current separation between
mainstream and later life lending
can mean outcomes depend more on
which adviser a customer happens to
speak to than on what is actually right
for them. That is not a position the
regulator is comfortable with.
No longer enough
One of the most important
implications for advisers is that the
long-standing defence of “this is not
my area” is becoming less robust. The
FCA is not saying advisers must advise
on every product type themselves, but
it is signalling advisers must be able
to recognise when a later life lending
option may be relevant and ensure the
customer is fully aware of this.
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The Intermediary | March 2026
For older borrowers, the risk of
harm oen comes from omission
rather than commission. A client
who takes a standard mortgage that
runs into retirement without any
discussion of alternatives may only
discover later the solution was never
sustainable.
From a regulatory point of view,
that raises questions about suitability,
foreseeable harm and whether
the advice genuinely reflected the
customer’s needs.
As expectations shi, advisers
will need to be more confident in
explaining why certain routes were
considered or ruled ou.
Triage at first contact
The FCA’s direction of travel points
towards much stronger assessment
at the very start of the advice process,
particularly for older clients. Advisers
should be asking themselves early on
whether a case is genuinely a standard
mortgage scenario, or whether factors
such as retirement timing, property
wealth or long-term affordability
change that view.
Clear triage does not slow advice
down. In fact, it reduces wasted
time, lowers risk and leads to beer
conversations. It allows advisers to
decide whether they are well placed to
advise across the full range of options
themselves, or whether the customer
would be beer served through a
managed referral to a specialist.
What maers is the decision is
conscious, documented and focused
on outcomes, rather than driven by
habit or comfort zones.
Holistic in practice
Holistic advice is a term that is oen
used loosely, but the FCA’s work
suggests we are likely to get a fairly
practical interpretation. At its core,
it should mean mortgage advice that
reflects how people actually live and
make decisions, rather than advice
that is constrained by historic
DAVE HARRIS
is CEO at more2life
market divisions. This means
recognising mortgages, retirement
income and housing wealth are closely
linked for many older clients. It
doesn’t mean an insistence on every
adviser advising across every single
option but it does mean advising every
single customer.
The challenge for firms will be in
deciding where they draw the line
between advising themselves and
referring, and then ensuring those
referral routes are clear, trusted and
well-governed.
Support is available
At more2life, we see our role as
helping advisers adapt to these
expectations with confidence rather
than concern. We support early
triage with tools and guidance that
help advisers understand when later
life lending should be part of the
discussion, and how those options
compare with mainstream routes.
Education remains a core focus,
not just around products, but around
how later life lending fits within
broader client needs. We also invest in
technology and upfront support that
give advisers clarity.
As later life lending continues
its move from niche to norm, the
advisers who will thrive are those who
engage with this shi early, improve
their front-end assessment, and build
advice processes that reflect real life
rather than old market boundaries. ●
