The Equity Release Council (“the Council”) welcomes the opportunity to respond to the Financial Conduct Authority’s Consultation Paper CP26/18 – Mortgage Rule Review: Responsible Lending.

To inform this response, the Council invited feedback from its membership following publication of the consultation. Eight detailed responses were received from organisations representing lenders, mortgage advisers, later life lending advisers and product providers, providing a broad range of practical insight from across the later life lending market. Members were invited to comment on all aspects of the consultation.

However, feedback was concentrated on those proposals with the greatest relevance to later life lending, particularly where changes could affect interest-only borrowing, Retirement Interest-Only (RIO) mortgages, regulated Lifetime Mortgages and the assessment of credible repayment strategies. Accordingly, this response focuses on those areas where members considered the proposals would have the greatest impact on consumers, advisers and lenders.

The Council has not sought to comment substantively on proposals outside its area of expertise where members did not raise material observations. Overall, respondents welcomed the FCA’s direction of travel and supported proposals that seek to modernise the mortgage framework by providing firms with greater flexibility whilst maintaining appropriate consumer protections. Members recognised that the mortgage market has evolved significantly in recent years and broadly supported reforms that enable firms to deliver better customer outcomes through more proportionate, outcomes-focused regulation.