Consumer Duty
Putting your interests first is not just good advice — it is a regulatory requirement. Here is how we live up to the FCA’s Consumer Duty every day.
How we help you pursue your financial objectives
The FCA Consumer Duty asks firms to do more than sell suitable products: we must act in good faith, avoid causing foreseeable harm, and actively support you in achieving what you set out to do — buying a home, protecting your family, or lowering the long-term cost of borrowing. These four commitments are how we do that on every case.
Products and services
We advise on a whole-of-market basis, so our recommendation must be the most suitable product for your circumstances, needs and risk profile from that search (MCOB 4.4A.6R) — not simply one that is adequate. We confirm the scope of advice in writing, keep a suitability record explaining why the recommendation is the most suitable, and decline to act if we cannot deliver a suitable solution.
Price and value
We compare total cost over the deal period, not just the headline rate. Fees, incentives, early-repayment charges and the follow-on rate are all part of the equation. We benchmark our own fee structure against the time, expertise and service involved, and we only charge a client fee where the advice is genuinely complex.
Consumer understanding
We explain our recommendation, the risks and the fees in plain language, give you a written summary, and confirm you understand the key points before you proceed. If something is unclear, we encourage questions and take extra time for customers who need it, including those with characteristics of vulnerability.
Consumer support
You can reach us by phone, email or the contact form during our published hours. We respond promptly, keep you informed from application to completion, and adapt our communication where a customer has accessibility needs or other characteristics of vulnerability.
Foreseeable harm
The adviser's role in avoiding foreseeable harm
A central part of our duty is to take reasonable care not to cause you foreseeable harm. Five things every adviser must do:
- 01
Understand your situation
We gather enough detail about your income, outgoings, future plans and vulnerabilities before making any recommendation.
- 02
Stress-test the recommendation
We consider how changes in interest rates, income, employment or personal circumstances could affect your ability to repay.
- 03
Spot and record risks
We identify risks that are reasonably foreseeable and document why the recommended product remains suitable despite them.
- 04
Decline where a product would harm you
If we cannot find a suitable solution, we will say so and explain the risks of proceeding without advice.
- 05
Refer or signpost when needed
If your needs fall outside our expertise, we will point you towards the right specialist or service.
Monitoring and evidence
How we check we are delivering good outcomes
Meeting the Consumer Duty is not a one-off exercise. We collect evidence throughout the year and review it formally at least annually, or sooner if a material issue arises.
File quality reviews
We sample completed advice files to check that the suitability record, research, disclosure and affordability assessment are complete and accurate.
Customer feedback and complaints
We record all complaints, analyse root causes, and use the findings to identify training needs, process changes or poor-value signals.
Vulnerable customer outcomes
We monitor whether customers with characteristics of vulnerability receive clear communication, reasonable adjustments and outcomes comparable to other customers.
Management information
We track service take-up, fees, commissions, product spread, lender panel use and completion times so the fair-value assessment is based on facts rather than assumptions.
At a glance
- Policy owner
- Geoffrey Arnold, Compliance Officer (SMF16)
- Complaints Officer
- Ian Arnold
- Scope
- All retail mortgage and protection advice
- Review
- Monitored continually, reported at least annually
What if your mortgage was solved, not sold?
Book a no-obligation fact-finding call with a qualified adviser. We’ll search the whole market and come back with a fully costed recommendation.