Turning the FCA’s Mortgage Regulatory Priorities into actionable insight

Mortgages Recordsure

The FCA has published its Regulatory Priorities report for the mortgages sector, setting out where it will focus supervisory attention over the year ahead. Covering mortgage and home finance lenders, administrators and intermediaries, the report is designed to give boards and senior leaders a stronger sight of regulatory expectations, bringing multiple strands of supervisory activity into one place. 

 

For the mortgage sector, this update comes at a time when the market has shown relative resilience. For instance, arrears have remained relatively low despite sustained pressure on interest rates. But the FCA is distinct in its emphasis that resilience alone is not the goal. Firms are expected to demonstrate how they are adapting to changing consumer needs and delivering good outcomes in practice, with the Consumer Duty embedded across the customer journey.

A mortgage market evolving in real time

A recurring theme in the report is the FCA’s recognition that the mortgage market no longer resembles what it was a decade ago. Consumers are buying later, borrowing for longer and increasingly, managing mortgage debt alongside other complex financial commitments into later life. 

 

The Mortgage Rule Review is the FCA’s vehicle for responding to these shifts. Its ambition is to create a framework that supports innovation and access, without compromising on responsible lending or consumer protection. For firms, this introduces both opportunity and challenge. Greater flexibility to meet customer needs, alongside higher expectations around how risks and outcomes are understood, monitored and evidenced. 

 

The FCA is clear that engagement matters. Firms are expected to contribute insight and data to inform how the framework evolves, particularly through consultations and focused work on laterlife lending. This reflects a broader regulatory direction towards evidence-led policymaking, where a firm’s ability to demonstrate what is happening for customers carries real weight. 

Responsible lending under closer, ongoing monitoring

Responsible lending remains a central pillar of the FCA’s priorities. The report places particular emphasis on affordability, not as a oneoff assessment, but as something firms should be actively reviewing as products, customer profiles, and economic conditions change. 

 

Rather than prescribing new rules, the FCA signals that firms should be able to show their affordability approaches remain appropriate and continue to deliver good outcomes. That places renewed importance on oversight, management information (MI) and the ability to identify emerging risks early. 

 

Support for borrowers in financial difficulty also remains firmly in focus. The FCA reiterates the need for timely, appropriate forbearance, with a clear expectation that firms can evidence how policies translate into realworld customer experiences. As pressures persist, this is an area where datadriven insight and consistent monitoring will be increasingly important. 

 

Second charge lending receives specific attention, with firms expected to reflect on recent supervisory findings and assess whether their affordability and expenditure assumptions genuinely reflect customer circumstances.

Advice quality and the full customer journey

Advice quality is the third headline priority set out in the report. The FCA’s focus here extends beyond individual advice interactions to the systems, controls, and assurance that underpin them. 

 

Firms are expected to ensure that advisers recommend products suitable for customers’ needs, including in more complex scenarios such as laterlife borrowing or debt consolidation. Recordkeeping and quality assurance are also highlighted, reinforcing the need for firms to be confident in the evidence they hold to demonstrate consistent delivery of good outcomes. 

 

Crucially, advice quality is tightly linked to the Consumer Duty. The FCA is clear that firms should understand and test outcomes across the customer journey, rather than relying on pointintime checks or assumptions about what “good” looks like. 

Governance, resilience and the role of technology

Beyond the headline priorities, the report brings together a broader set of supervisory themes, including operational resilience, disorderly failure planning, conflicts of interest, appointed representative oversight, Senior Managers and Certification Regime (SMCR) accountability and the use of technology and AI. 

Taken together, these areas signal a regulatory focus on how well firms really understand what is happening within their businesses. Strong governance increasingly depends on timely, accurate insight – not just policies and controls, but the ability to evidence how those controls operate in practice as firms scale, outsource and adopt new technologies. 

Turning regulatory priorities into insight

For boards and senior leaders, the value of the Regulatory Priorities report lies in the direction it sets. The FCA is clear about where it will look, the outcomes it cares about and the evidence it expects firms to have at their fingertips. Firms that can surface insight quickly, monitor outcomes effectively and respond early to emerging risks are better placed to operate confidently in that environment. 

 

Technology has a growing role to play here – not as a replacement for judgement, but as an enabler of better oversight, stronger assurance and more meaningful MI. 

How Recordsure supports mortgage firms

Recordsure helps mortgage firms capture, analyse and evidence customer interactions at scale. Our Capture creates a reliable audio record of client conversations – whether in person or online  and turns conversations into meeting summaries. Recordsure AI applies advanced speech and document analytics to transform how oversight is delivered. With broader coverage, smarter automation and richer MI, firms gain clearer insight into advice quality, emerging risks and customer outcomes, enabling faster, more confident decisionmaking.   

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