The FCA’s attention on second-charge lending and debt advice reinforces a clear message: affordability evidence, accurate expenditure capture and suitable recommendations matter most where customers may be financially vulnerable. The regulator has highlighted concerns where important spending was overlooked or consumers were steered toward unsuitable fee-charging debt solutions.
For mortgage advisers using AI-enabled workflows, technology should strengthen—not shortcut—fact-finding and compliance. Useful controls include
- flagging incomplete income, expenditure or vulnerability information;
- requiring advisers to record why a second charge, remortgage, consolidation route or referral is suitable;
- maintaining human approval and an auditable record of advice.
The FCA’s wider financial-crime findings also make robust identity, fraud and anomaly checks increasingly relevant across the home-finance journey.