February marks the Equity Release Council’s Fair Value Month, providing a focused opportunity to reset the baseline on fair value under the Consumer Duty and revisit what the Financial Conduct Authority now expects in practice. That is why the Council will be running Fair Value February, a practical opportunity to pause, revisit regulatory expectations and sense check current approaches, while focusing on the move from frameworks to clear evidence of fair value in practice. Over the coming weeks, we will revisit key FCA messages, highlight examples of good and poor practice, and focus on the shift from frameworks to evidence of fair value in practice. We have published the first Fair Value February Member Briefing, Fair Value under the Consumer Duty: What the FCA expects and what members should do now, which brings together recent FCA outputs and sets out practical considerations for providers and advisers. To view the briefing, click here.
The FCA has made clear that later life lending is firmly on its regulatory radar. In this piece, Kelly Melville-Kelly, Deputy Chief Executive at the Council considers what the latest feedback statement means for fair value, confidence and readiness across the market. She also outlines how firms can take practical steps to prepare for what comes next.
The Financial Conduct Authority’s (FCA) recent Feedback Statement FS25/6 and its accompanying roadmap landed in my inbox while I was in the Alps, attempting to convince myself that skiing is something I am naturally good at. It turns out it is not. But it did give me a rare quiet moment to read the statement properly and reflect on what it really means for later life lending.
What struck me most was how clearly the FCA is signalling that this market matters. The announcement of a focused market study should be seen as positive news. It reflects growing recognition that later life lending will play an increasingly important role as consumer needs evolve, and that the focus now is on ensuring the market is ready to grow well.
This is not a moment to wait to be told what to do next. The direction of travel is already clear. The Consumer Duty, and particularly the Price and Value outcome, now places responsibility on firms to be able to demonstrate fair value in practice, supported by evidence, monitoring and governance.
For advisers, this is about confidence. Confidence in explaining the value of advice and services, confidence that charges remain reasonable relative to outcomes, and confidence that this can be evidenced if asked. For firms more broadly, it is about moving from frameworks that exist on paper, to frameworks that are actively used.
My time in the Alps was a reminder that just because something feels difficult, it does not mean it should be avoided. Sometimes the only way to make progress is to go back to the beginning, focus on the fundamentals, and put the effort in.
Don’t forget to register for the live webinar “From frameworks to evidence – demonstrating fair value in practice” which will be delivered in partnership with Deloitte on Wednesday 18 February 2026 at 10am. Click here to register.
