The FCA must clear the path for advisers to give older borrowers the advice they deserve – Harris

For the first time, later life lending wasn’t a footnote – it had a chapter all of its own, asking whether property wealth should play a bigger role in retirement and what’s holding advisers back from talking about these options. 

We’ve sent in our response, and we believe the messages we are delivering are clear. We believe one of the main barriers facing advisers isn’t demand, it isn’t product supply, and it isn’t a lack of customer need. It’s structure.

Too many rules, too many silos, and too much confusion about what advisers can and can’t do. 

Limited by qualifications 

Take qualifications. Today, we’ve got thousands of mortgage advisers, but only a fraction are able to talk about lifetime mortgages because of the extra hurdle of Certificate in Regulated Equity Release (CeRER).

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That means thousands of customers over 55 can go through a mortgage review without the full range of later life options, including modern lifetime mortgages, ever being mentioned – even when it might be the best fit for their circumstances.

That cannot be right.

We believe CERER should be absorbed into Certificate in Mortgage Advice and Practice (CeMAP) so all advisers have the grounding they need. If an adviser still wants to refer on for another adviser to cover certain elements, that’s fine, but customers should never be left in the dark simply because of their initial choice of adviser. 

Limited by regulation 

Then there are the advice silos baked into the rulebook. The Mortgages and Home Finance: Conduct of Business (MCOB) separates mainstream and later life mortgages, even though modern products now overlap far more than they diverge.

Advisers are still expected to think in product boxes, when in reality, what matters is the customer’s age, circumstances, and long-term goals. If you’re advising a 57-year-old with mortgage debt and limited pension savings, the conversation should naturally include lifetime mortgages and retirement interest-only (RIO) mortgages alongside standard remortgage options to ensure they’re thinking more holistically about their situation.

Right now, too often, it doesn’t. 

Treating mainstream and later life mortgages as a complete financial journey

What we are asking the FCA to do is actually very simple: create one seamless advice journey. To no longer treat later life lending as something that sits on the fringes and bring it into the mortgage ‘universe’.

That means unified qualifications, consistent disclosure requirements, and a single set of rules that allows advisers to focus on outcomes rather than definitions. 

For advisers, this isn’t about more red tape. Quite the opposite. If we get this right, it will remove barriers, reduce uncertainty, and deliver the confidence to have broader conversations with clients in their 50s and 60s. It will also give customers the reassurance that whatever adviser they speak to, they’ll be shown the full picture, not just a narrow version of it. 

It’s worth stressing this debate isn’t about waiting for the next big product breakthrough.

Lifetime mortgages have already evolved significantly – More2life’s product offering is proof of that, with features such as Interest Reward, voluntary repayments, drawdown facilities, downsizing protection, zero early repayment charges (ERCs) and fixed-for-life rates.

The products are here, but too few people can access them at the right time. 

That matters because the customer need is undeniable. We have millions of borrowers heading into retirement with outstanding mortgage debt. We know from our own data that many use later life products to repay those mortgages, adapt their homes, or help children and grandchildren onto the housing ladder.

And we know from wider research that unlocking property wealth can deliver not just personal benefits but wider economic gains. Our own lending has already contributed an estimated £11bn in economic value over the past five years. 

The future of later life lending depends on change

So, the case for action is strong. Advisers are willing, customers are in need, and the solutions are on the table. The FCA now has the chance to unlock all of this by clearing away the unnecessary complexity and giving everyone involved the confidence to move forward. 

My message to advisers is this: the future of later life lending isn’t going to be defined by another product launch, although there will, I’m sure, be plenty more of these to come. It’s going to be defined by whether you’re equipped and supported to bring these conversations into your everyday advice process.

That means one qualification, one rulebook, and one clear expectation that customers in later life should always see all their options. That’s the future we’ve set out in our response, and it’s the future we believe the FCA must deliver.