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FCA has no plans to enforce changes to execution-only disclosure documents

  • 28/05/2019
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FCA has no plans to enforce changes to execution-only disclosure documents
Mortgage Solutions understands that the Financial Conduct Authority (FCA) has no plans to either enforce or to recommend a change in the way disclosure documents are produced.


This is despite research commissioned by the regulator which found that consumers do not always understand the protections they are losing when they complete mortgages by execution-only.

Mortgage Solutions first published details of the research earlier today, and the FCA has since responded to questions about the results.

Overall, it is believed the regulator is satisfied that consumers generally understand they are buying a mortgage without advice and so fundamentally the disclosure is working.

As a result, it seems the regulator will not be requiring firms to change the way they operate their execution-only disclosures.

However, the report was produced with the intention of suggesting ideas for lenders or other firms conducting execution-only sales to alter their disclosure documents to improve consumer understanding.


Numerical results not available

The research was conducted around the turn of the year with 30 in depth interviews and four focus groups.

It was undertaken as qualitative research, based on the interviews and focus groups, rather than people completing a questionnaire.

As a result, a numerical breakdown of the subjects, such as the proportion of interviewees that did not understand the protections they were giving up, is not available.

The regulator already requires disclosure to be conducted before a consumer decides to proceed with an execution-only purchase, and it is unlikely that it will suggest firms change the timing in which this is done.

However, firms may repeat the disclosure further along the process if they wish.

Mortgage Solutions understands that key areas covered in the interviews and focus groups included:

  • The mortgage application journey,
  • Formal or informal advice received, and attitudes towards it,
  • Testing of anonymised disclosure document,
  • And other world document testing.


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