FCA Compliance for Mortgage & Home Finance Firms
Specialist regulatory support for mortgage businesses across ongoing FCA compliance, MCOB, Consumer Duty, advice and sales controls, appointed representative oversight and regulatory remediation.
We work with brokers, lenders, networks and principal firms to test how advice is actually being given, evidence customer outcomes and put right weaknesses before they become supervisory issues.
Mortgage Brokers
MCOB, suitability, disclosures and file quality.
Networks & Principals
AR onboarding, monitoring and annual reviews.
Lenders
Responsible lending, forbearance and governance.
Assurance
File reviews, independent audits and remediation.
How We Support Mortgage Firms
Ongoing Compliance Support
Compliance monitoring, policies, regulatory change, governance and senior technical support for firms that need additional capacity.
MCOB Compliance
Review of conduct arrangements across disclosure, advice, suitability, execution-only routes, arrears and charges where applicable to the firm's permissions.
Consumer Duty
Outcome testing, fair value considerations, consumer understanding, consumer support and the evidence needed for board assessment.
Advice and Sales Controls
Review of governance around suitability, disclosures, sales practices and how customer outcomes are evidenced across the adviser population.
File Reviews & Quality Assurance
Structured, risk-based file testing with calibrated scoring, thematic findings and a practical route to improving quality at source.
Affordability & Responsible Lending
Review of relevant controls and assessment arrangements where applicable to the firm's activities and permissions.
Vulnerable Customers
Review of whether policies and operational practices appropriately identify and support customers with characteristics of vulnerability.
Principal & AR Oversight
Due diligence, onboarding, monitoring, governance, annual reviews, management information and remediation for mortgage networks and other principal firms.
Compliance Audits
Independent regulatory reviews with prioritised findings and practical remediation.
FCA Supervision & Remediation
Support where the FCA has requested information, raised concerns or requires remedial action.
Who We Support
- /mortgage brokers and intermediaries
- /mortgage lenders
- /mortgage networks
- /principal firms
- /appointed representatives
- /second charge mortgage firms
- /home finance businesses
- /firms advising on or arranging regulated mortgage contracts
Not every service applies identically to every firm. Obligations differ between advising, arranging, lending and administering, and between directly authorised firms and appointed representatives operating under a principal.
Regulatory Framework
The provisions most frequently in scope for mortgage and home finance firms include the following, subject to the firm's permissions.
MCOB
Conduct requirements for regulated mortgage contracts and home finance, including disclosure, advice, suitability and arrears handling.
Consumer Duty (PRIN 2A)
Cross-cutting rules and the four outcomes, with associated monitoring and board reporting expectations.
Principles for Businesses
The overarching conduct standards applied by the FCA.
SYSC
Governance, systems and controls, and the compliance oversight function.
DISP
Complaints handling, root cause analysis and Financial Ombudsman Service outcomes.
SUP
Supervisory notifications and regulatory reporting.
Financial promotions
Approval, records and the standards applied to promotions across advisers and ARs.
SM&CR
Senior manager responsibilities, certification and Conduct Rules.
Appointed Representative requirements
Principal obligations for appointment, oversight and notification.
Typical Reasons Mortgage Firms Engage Us
compliance monitoring needs strengthening
file review results reveal recurring weaknesses
Consumer Duty evidence is insufficient
the firm has expanded its adviser or appointed representative population
FCA correspondence requires a structured response
quality assurance needs to become more robust
policies no longer reflect actual operations
a board wants independent assurance
remediation is required following an internal or external review
Services for Mortgages & Home Finance
FCA Compliance Support
Senior compliance capacity for mortgage firms.
Learn moreCompliance Audit
Independent review and file testing.
Learn moreConsumer Duty
Outcome evidence for advice and lending.
Learn moreSM&CR
Certification, fitness and propriety and Conduct Rules.
Learn morePrincipal & AR Oversight
Network and AR supervision frameworks.
Learn moreRegulatory Reporting
Reporting calendars, validation and notifications.
Learn moreFCA Supervision & Remediation
Responding to FCA scrutiny.
Learn moreLicensing & Authorisation
Authorisation and variation of permission.
Learn moreMortgages & Home Finance Compliance FAQs
Scope is set against the firm's permissions. A typical review covers governance and the compliance monitoring programme, MCOB conduct requirements, advice and suitability controls, disclosure and financial promotions, Consumer Duty outcomes and evidence, vulnerable customer arrangements, complaints and root cause analysis, adviser and appointed representative oversight, training and competence, and regulatory reporting. Findings are prioritised by regulatory risk.
Yes. We run risk-based file testing using calibrated criteria so that results are comparable across advisers, offices and appointed representatives. Output includes individual file findings, thematic issues, an assessment of whether weaknesses are systemic and recommendations that address the cause rather than the symptom.
The recurring issues we see are suitability evidence that does not explain why the recommendation was appropriate for the customer's circumstances, inconsistent disclosure, weak documentation around execution-only and non-advised routes, insufficient consideration of vulnerability, fees and charges that are not clearly evidenced as fair value, and quality assurance that samples too narrowly to detect systemic weakness.
The Duty applies across the four outcomes and requires evidence rather than intent. For mortgage firms this typically means demonstrating that advice consistently delivers good outcomes, that fees and charges represent fair value, that communications are understood by customers rather than simply issued, that support is accessible at the point customers need it, particularly in arrears, and that outcome monitoring reaches the board in a form it can act on.
Yes. We support principal firms with pre-appointment due diligence, onboarding, ongoing monitoring and testing, financial promotions oversight, annual reviews, management information, regulatory notifications, offboarding and remediation where oversight has not kept pace with growth in the AR population.
Yes. Retained support is structured around scheduled compliance input, technical escalation, regulatory change, policy review, monitoring and board or committee reporting. It sits alongside the firm's existing team rather than replacing an internal compliance officer or senior management function.
Yes. We help firms understand what the regulator is testing, assemble and pressure-test the underlying evidence, identify weaknesses before the regulator does, draft accurate responses and implement remediation with follow-up testing to demonstrate that the fix has worked.
Discuss your regulatory position
Tell us where the pressure is and we will tell you, candidly, what we would do about it. Initial discussions are free and without obligation.