26 February 2026
Fair Value February may be drawing to a close, but the work is not.
Hear from Kelly Melville-Kelly, Deputy Chief Executive and Director of Risk, Policy and Compliance, as she reflects on the Council’s Fair Value February programme and how we move from framework to everyday practice.
There was a moment when fair value felt like a project.
A deadline. A framework. A job done.
Tick.
But fair value was never meant to be a document. It was meant to be discipline. And disciplines do not live in board packs, they live in behaviour.
When Consumer Duty came into force, firms quite rightly focused on building frameworks, documenting methodologies, and securing board approval. That was the starting point. It was never the destination.
The direction of travel from the regulator has been clear. Fair value is not a one-off exercise. It must be assessed, challenged, monitored, and evidenced on an ongoing basis. The expectation is no longer that firms can simply describe their approach. They must demonstrate how it operates in practice and how it leads to action.
Fair value does not mean the cheapest. It means the price paid is reasonable relative to the benefits, features, risks, and service received, taking into account the needs of the target market and the total lifetime cost.
For providers, that requires clear target markets, structured methodologies linking price to benefits, meaningful management information and genuine governance and challenge. For advisers, it means being able to articulate what customers receive in return for fees, reviewing ongoing services and evidencing that value continues to be delivered.
In later life lending, this matters deeply. Customers frequently experience the benefit straight away, clearing debt, funding care, or gifting to family. But the structure of a lifetime mortgage is long term, and its effects endure. When someone is making a once in a lifetime decision about their home, often at a vulnerable moment, value cannot just be demonstrated at completion. It has to stand up over time.
That is why throughout February we focused on practical support. We refreshed guidance, issued briefing materials, and encouraged members to sense check their frameworks against published good and poor practice.
As part of that programme, we hosted a webinar in partnership with Deloitte, ‘From frameworks to evidence, demonstrating fair value in practice’. The session explored proportionality, common pitfalls and the role of management information, governance, and challenge.
We began with a simple temperature check, asking when firms had last reviewed their fair value assessment.
71% said they had reviewed their fair value assessment in the last six months.
34% said they have only reviewed their fair value since the start of Fair Value February.
We closed by asking what would happen next.
75% said they were very likely or likely to review or update their fair value assessment within the next four weeks.
45% percent committed to a full review or targeted updates.
59% percent said they would schedule an internal discussion or seek external advice.
We were also thrilled to discover that 96% of attendees surveyed found the webinar valuable.
That is the real so what.
If those commitments translate into stronger monitoring, clearer articulation of adviser value and more robust board challenge, customers will benefit. That is where fair value moves from compliance to culture.
Fair value is no longer about proving we have considered value. It is about proving customers are receiving it and being able to evidence that confidently if asked.
February was not about revisiting the rulebook. It was about reinforcing a mindset. In a market as important and sensitive as later life lending, that mindset is fundamental.
If you have not reviewed your fair value assessment recently, it is worth pausing to ask why.
Is it because you are confident it is robust? Or because it has slipped down the priority list?
In a market where customers are making significant decisions about their homes, that is a question every firm should be comfortable answering.
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