The Intermediary – November 2025 - Flipbook - Page 67
RESIDENTIAL
Opinion
be vital to help consumers navigate
options” but at the same time, it agreed
to a change that stripped away access
to advice altogether, via the removal
of the advice interaction trigger, for
existing borrowers communicating
direct with lenders.
How do those two things marry up
in a Consumer Duty world?
The world of tomorrow
I’ll give Rathi his dues, the speech was
full of fine words about collaboration,
innovation and consumer wellbeing.
But for advisers, the problem isn’t
the sentiment, it’s the inconsistency,
the fact this theory hasn’t married up
with the practice, and that the future
journey looks to be going off further in
this direction.
If you believe, as I do, that advice
is a force for good, and that by
taking advice consumers have a far
beer chance of achieving a positive
outcome, then you don’t need to
“think differently” about this. The
FCA might believe the market needs
to, but we don’t.
This is already a market in which
advice dominates for a reason. More
than 90% of new mortgages come
through advisers. It’s a market which,
in Rathi’s own words, is “serving
millions of customers well.” So why is
the regulator seemingly determined to
fix what isn’t broken?
This Mortgage Rule Review, Rathi
said, isn’t about the market today, but
the market of tomorrow. That’s fine to
a point. But you can’t write a rulebook
for a market that doesn’t yet exist.
And you can’t simply have blind faith
that technology and AI are going to
comfortably deliver the same positive
outcomes that advice does, just
because the big lenders tell you it will.
Reading Rathi’s speech, you might
think the FCA is fully behind advisers
– that it sees us as central to fair value,
strong outcomes, and sustainable
homeownership.
Yet too oen, the FCA cherry-picks
its position depending on who it’s
talking to. One week advice is the
heartbeat of the market, and the
next it’s too dominant and needs to
be reined in. That’s not a sustainable
position, and it doesn’t square with
Consumer Duty.
Consumers overwhelmingly want
advice. They value it. They seek it
out. That’s why the advised channel
is dominant. Yet we appear to have
a regulator that feels it’s important
SEBASTIAN MURPHY
is group director at JLM
Mortgage Services
to support other channels over ours,
to directly sign-post these channels,
and to have blind faith that AI and
tech will make everything right,
when it’s really a play to help bring
lender’s cost base down at the expense
of quality outcomes.
I wish every adviser could have been
in the room to hear this, because it
was worrying in the extreme. What
the regulator thinks is ‘being bold’ felt
more like a reckless experimentation
with a market that isn’t broken. And
that should concern us all. ●
November 2025 | The Intermediary
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