The Intermediary – September 2026 - Flipbook - Page 98
T E C H N O L O GY
Opinion
Only as good
as the data
W
hen it comes
to regulation
in the UK
mortgage
market, there
is oen value
in read-across of general principles.
In July, the Financial Conduct
Authority (FCA) published a
market view relating to firms’
implementation of the Consumer
Duty – ‘Outcomes monitoring: good
practice and areas for improvement’.
The regulator warned what we all
know, that management information
alone does not demonstrate good
customer outcomes. A valuation
dashboard may show a figure,
a confidence score and a rapid
turnaround time, but those metrics
do not prove that the property
information behind a lending decision
is appropriate for the risk being taken.
A mortgage valuation is most oen
discussed as though it were a discrete
event, when a property is assessed,
a value assigned and the lending
process moves on. In practice, it is
the output of information that can
include transaction records, property
aributes, local market evidence and
modelled assumptions.
Each input has a source, date, degree
of coverage and potential limitation,
meaning the quality of the conclusion
depends on how well those factors are
understood and governed.
This is increasingly important as
lenders seek timely decisions. HM
Land Registry’s Price Paid Data,
updated monthly, provides an official
record of sales for value in England
and Wales that have been lodged
for registration. It is a valuable
component of property intelligence,
yet no individual dataset can explain a
property in full.
Lenders must understand how
recently information was recorded,
whether it is comparable to the
security being assessed and how it
relates to other evidence.
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The Intermediary | September 2026
The FCA’s July review usefully
reframes the standard. The regulator
found that some firms relied on
lagging indicators, lacked clear
thresholds or did not maintain audit
trails from identifying an issue
through to action and outcome. It also
highlighted gaps and inconsistencies
in key data that limited firms’ ability
to evidence customer outcomes.
The implications for valuation
governance are clear: lenders should
be able to trace material property
information, establish when it was
refreshed and understand how a
conflict, exception or model override
was resolved.
That is more demanding than
retaining a final value. Valuation
data should be treated as a governed
decision record, and if an automated
process identifies a property as
materially different from its
comparables, that should be visible.
If performance changes in a
particular geography or property
type, the lender needs a threshold
for intervention. If a surveyor’s view
departs from automated evidence,
the difference should be capable of
informed challenge. Good governance
gives expert judgement a clear
evidential foundation.
Beyond origination
Property risk changes over the life of a
mortgage. Local transactions, physical
condition, leasehold arrangements,
energy performance and planning
decisions can alter the lens through
which a lender views a security.
A portfolio assessed sensibly
at completion can still develop
concentrations of risk if property
information is not refreshed,
interpreted and connected to the risk
framework. Lenders need to identify
cases requiring aention before a
refinancing event or change in risk
appetite exposes the weakness.
There is also a security and
resilience dimension. Mortgage
MARK BLACKWELL
is chief operating officer
at Cotality
valuation workflows draw on data
suppliers, surveyors, models,
geospatial tools and cloud-based
platforms. HM Treasury reported
in July that 82% of surveyed UK
banks, insurers and asset managers
regarded cyber aacks as a top-five
systemic risk.
Only 10% of organisations reported
preparedness for AI-augmented
cyber threats. A lender that cannot
establish a data feed’s provenance,
identify where it is used or recover
it aer disruption may be relying
on an incomplete view of the asset
supporting the loan.
The Bank of England has
reinforced that concern,
warning that frontier artificial
intelligence (AI) can accelerate
the identification and exploitation
of soware vulnerabilities. It has
urged firms to reconsider whether
recovery arrangements and key
technology providers remain
sufficiently resilient.
For lenders using more automated
property intelligence, this is a
reason to strengthen governance
before scaling usage. They need
clear visibility of ownership of data
sources and an understanding of
which lending decisions would be
affected if a provider were unavailable
or compromised.
The future of mortgage valuation
will depend on how effectively
lenders make sense of growing
volumes of property information.
The lenders best placed to use that
information well will be those that can
demonstrate its lineage, protect
its integrity and apply it with
appropriate judgement. ●
