more2life responds to FCA Discussion Paper 25/2 urging regulator to create the conditions for later life lending to deliver to its full potential

more2life, the later life lender, has issued its response to the FCA’s Mortgage Market Discussion Paper (DP25/2), welcoming the regulator’s recognition of later life lending as central to the mortgage market of the future, but warning real progress will only be made if outdated regulatory barriers are removed and advisers are empowered to consider all options for older borrowers.

As one of the UK’s largest later life lenders, more2life believes Chapter 3 of the FCA’s DP can be a landmark moment for the sector, but argues proposals must now be followed by action.

It reasons that without regulatory reform, millions of homeowners approaching retirement risk being left without access to all the available solutions that could improve financial resilience, enhance living standards and support wider societal and economic goals.

To address this, more2life’s response highlights five areas where regulatory change is needed:

• Removal of advice silos. The current separation of mainstream and later life mortgage advice under MCOB means that whether a consumer is shown all their options may depend on what type of adviser they approach. The lender believes this is unacceptable. more2life supports amalgamating the relevant rules so every borrower over 55 receives holistic mortgage advice by default.
• Unifying adviser qualifications. The lender says the current requirement for a separate CERER qualification is outdated and reinforces barriers. more2life believes the content should be absorbed into CeMAP so all advisers have a baseline understanding of later life options, while retaining the ability to refer cases where necessary.
• Providing clear regulatory guidance. Lifetime mortgages are still sometimes seen as a ‘last resort’, despite significant product evolution. more2life says the FCA should issue explicit good and poor practice guidance for later life lending, to build confidence, reduce stigma and ensure advisers can engage with these products without fear of regulatory censure.
• Mandating disclosure of options. Later life borrowers should never reach the end of a mortgage term without being told about later life solutions. more2life is calling for mandatory disclosure requirements on both lenders and advisers, so customers are always made aware of the choices available to them at key points in their mortgage journey.
• Supporting innovation. The FCA has asked how regulation can better support product innovation. more2life argues rule changes are needed to allow hybrid and flexible products to reach their target markets, with current silos acting as a brake on development and adoption.

In making its case, more2life pointed to the range of innovations already in the market that are delivering tangible benefits for customers.

This includes: the fact around 40% of its lending is in drawdown lifetime mortgages; Interest Reward product availability offering a discount for making repayments over a set period; downsizing protection helping customers move without early repayment charges; intergenerational support continuing to grow as a driver of demand, with lifetime mortgage customers providing financial help to children and grandchildren, often to support first-time buyer deposits.

Alongside product development, more2life said it has invested in a number of tools and processes to support advisers, who it sees as the true gateway to change. Its ProView proposition provides upfront underwriting and property insight, enabling a 90% application-to-offer conversion rate compared to 58% for non-ProView cases.

more2life said the impact of these innovations is not limited to individual households with its lending activity over the past five years estimated to have generated £11bn in wider economic benefit.

Customers use housing wealth to repay debt, adapt their homes, fund care needs, or support family members – all of which stimulates spending and reduces pressure on public services.

Yet despite these benefits, more2life warns too many older homeowners are still not being shown the full picture. Consumer awareness remains low, adviser participation needs to improve, and perceptions of regulatory risk too high.

Without FCA action to change the rules and provide clear guidance, more2life says millions risk missing out on the opportunity to use housing wealth to secure a more comfortable retirement.

Dave Harris, CEO at more2life, said
“The FCA’s Discussion Paper, and the specific chapter on later life lending, is a recognition of how important it has become, but recognition is only the first step. The next is action. Older borrowers need advice that reflects their full range of options, not advice determined by whether their adviser happens to hold a separate qualification.

“Our experience shows that when customers are made aware of lifetime mortgages, the outcomes are overwhelmingly positive. Drawdown and Interest Reward products help people manage borrowing costs and build financial resilience. Hybrid models can bridge the gap between mainstream and lifetime mortgages. Downsizing protection and voluntary repayments give people flexibility. These solutions are already here. What is missing is the regulatory framework to ensure more people can access them.

“Lifetime mortgages are not a product of last resort. They are helping customers repay debt, stay in their homes, adapt their properties, and support their children and grandchildren. They are also creating broader benefits; as we state, our lending alone has generated an estimated £11bn wider economic impact in just five years. Imagine the difference if every older borrower had the chance to consider these solutions as part of a normal advice journey.

“The FCA has asked the right questions. Now we need it to deliver the right answers: one advice journey, consistent qualifications, mandatory disclosure of later life options, and clear guidance that gives advisers the confidence to act. We are ready to play our part, but the framework has to evolve if later life lending is to achieve its full potential.”