Joined‑up advice. Clear accountability. Better outcomes.

The FCA’s recent activity leaves little room for doubt: later‑life lending is firmly under regulatory scrutiny.

Through its market study into later‑life mortgages, the FCA is examining whether lifetime mortgages and retirement interest‑only (RIO) products are evolving in a way that genuinely meets consumers’ changing financial needs. This includes a close look at distribution and advice models, consumer decision‑making, and whether customers receive clear, holistic advice at the right point in their journey.

This work sits squarely within the expectations of Consumer Duty.

While firms are not required to advise on every possible solution, the direction of travel is clear, fragmented journeys and informal hand‑offs are no longer sufficient, particularly where decisions are complex, long‑term and difficult to reverse, as they often are in later‑life planning.

Why this matters for mortgage and wealth firms

Borrowing patterns are changing. Mortgage terms are extending further into later life, pension provision remains insufficient for many customers, and more people are relying on housing wealth as part of their wider financial picture.

As a result, equity release is increasingly part of broader conversations, even when it falls outside a firm’s core advice scope.

Under Consumer Duty, the expectation is not that every firm becomes a later‑life lending specialist. The expectation is that:

• customers are not left unsupported when equity release becomes a relevant consideration
• options are explored by someone with the appropriate expertise
• responsibility for advice and outcomes is clear, appropriate and suitable, providing the customer with a good outcome. 

From a customer outcomes perspective, the risk is no longer just product choice, it is how consumers are supported to make decisions, and whether that support stands up to scrutiny.

Holistic advice doesn’t mean advising on everything

The FCA has been explicit that firms can define the scope of their advice. However, it has also been clear that holistic advice means joined‑up thinking, with clear referral where advice falls outside that scope.

In practice, this means mortgage and wealth firms need:

• a defined process for identifying when later‑life lending may be relevant
• a structured referral route to specialist advice
• confidence that the customer journey remains outcomes‑led beyond the referral point.

Many firms feel tension here, not because they wish to extend their permissions, but because they want reassurance that doing the right thing for customers is also the right thing under Consumer Duty.

Our approach to advice and customer outcomes

In my role as Director of Customer Outcomes at Key, I am accountable for ensuring that customers experience good outcomes in practice, including across the partnerships and advisers operating through Key Partnerships.

Later‑life lending decisions are often complex, long‑term and difficult to reverse. Because of that, we do not start from the assumption that equity release is the right answer; we start by understanding the customer’s needs and whether alternative options may be more appropriate.

Advisers operating through Key Partnerships are expected to approach these conversations with care, professional judgement and a clear focus on customer understanding and long‑term suitability. In practice, this means:

• supporting customers to understand their options
• considering whether equity release is appropriate in the context of wider circumstances
• recognising vulnerability and longer‑term implications
• ensuring decisions are informed, rather than progressed for their own sake.

This shared approach underpins our governance and oversight, and reflects how we interpret our responsibilities under Consumer Duty. It is not about positioning ourselves differently, it is about being clear on the standards we work to and why they matter for customers making later‑life financial decisions.

How Key Partnerships supports firms under Consumer Duty

Key Partnerships supports mortgage and wealth firms when equity release becomes a relevant part of the customer journey, without requiring those firms to extend their own advice scope.

Our role is clear and defined:

• regulated, specialist equity release advice delivered by experienced Advisers
• consideration of equity release alongside relevant alternative options
• suitability, vulnerability and long‑term impact embedded throughout the advice process
• clear accountability for advice and customer outcomes. 

This allows partner firms to remain confidently within their own scope, while ensuring customers receive appropriate specialist support when later‑life lending forms part of the conversation.

Doing the right thing – with clarity and confidence

The FCA’s market study reinforces a direction of travel many firms are already experiencing, later‑life advice cannot be an afterthought, and referral arrangements must be deliberate, governed and outcomes‑focused.

Having a specialist referral route in place is not about adding complexity. It is about removing uncertainty for customers, advisers and firms alike.

At Key, that is the standard we work to and the responsibility we take seriously.