The Intermediary – June 2025 - Flipbook - Page 31
the use of tech in execution-only models, an area
that should be closely monitored by regulators
and industry leaders alike.
Hutchins sees changes to the interaction
trigger as particularly impactful for both
REGULATORY
Milestones
customer experience and how lenders operate.
“We believe, based on members’ feedback,
that amending the interaction trigger
should have the most significant impacts,”
she says.
"Amending the interaction trigger will allow
lenders to improve their customer choice and
reduce friction in the preferred channel that the
customer wants to discuss their mortgage.
"This should avoid them being forced down and
advised through unnecessarily.”
Hutchins adds that this should help lenders
support confident customers making their own
decisions by providing clear facts without veering
into advice.
She says: “We expect this change to largely
benefit the cohort of customers that are most
confident in making decisions about their
mortgage. So, we don't anticipate it having a
negative impact on brokers.”
A future-proofed approach
As regulation in UK lending continues to evolve,
adaptability will be essential. The most successful
firms will treat compliance not as a burden, but
as an opportunity to build trust and stand out
in a crowded market. Advice is set to become
a value-added service, tailored to the customer
rather than simply a regulatory checkbox.
The best providers will aim not just to meet
minimum requirements, but to exceed them
– delivering both compliance and a positive
customer experience.
Singh cautions that the threat for advisers
is “not just regulatory, it’s existential,” urging
firms to stay engaged and vocal as the FCA’s
reforms shift the sector toward more direct
distribution. He believes that advisers who adapt,
maintain their professional standards, and
embrace new technologies will be best placed to
thrive in the years ahead.
Looking forward, regulation will remain on
everyone's minds – shaping product design,
consumer protection, and innovation.
Haq believes that collaboration between
the FCA and industry can deliver both better
outcomes and new opportunities, while Shand
encourages firms to use regulatory change to
enhance both fairness and efficiency.
As the industry awaits the FCA’s final word on
CP25/11, the work of future-proofing lending is
already underway – one process, one policy, and
one customer journey at a time.
●
◆ PS12/16: Mortgage Market Review
(MMR) rules (2012) – Overhaul of
mortgage affordability and advice
requirements following the Global
Financial Crisis.
◆ CP11/31: Building the Rulebook
(2011) – Early consultation on
mortgage reforms.
◆ TR14/20: Thematic Review of
Responsible Lending (2014) – Stresstesting and oversight of responsible
lending practices.
◆ PS18/14: Senior Managers &
Certification Regime (SM&CR) (2018)
– Greater personal accountability
for senior management in
financial services.
◆ PS19/14: Switching Simplified (2019)
– Easier mortgage switching
for consumers.
◆ PS22/9 / FG22/5: Consumer Duty
(2022) – Outcomes-focused regulation
raising standards for firms and
customer outcomes.
◆ GC22/2: Fair Value Guidance (2022)
– Clearer expectations for delivering
fair value to customers.
◆ CP25/11: Mortgage Rule Review
(MRR) (2025) – Proposals to simplify
rules and increase flexibility in
mortgage lending and advice.
