Regulatory

Fair Value

Fair value means the benefit you receive is proportionate to what you pay. We apply that test to our advice, the products we recommend, and the service you experience throughout.

What fair value means for you

When we assess fair value, we look at the total cost of the service and the product together, the quality of advice, the benefits you should receive, and whether the outcome is right for your circumstances. It is not simply about finding the lowest rate or the lowest fee. It is about making sure the overall package — advice, mortgage, protection, fees, and ongoing support — delivers genuine value.

01

Total cost comparison

Rate alone can be misleading. We compare monthly payments, arrangement fees, valuation fees, incentives, early repayment charges and the full cost over the deal period. We then identify the product that offers the best overall value from those available to us through our whole-of-market research.

02

Suitability, not just price

A cheap mortgage is not fair value if it does not fit your needs. Under MCOB 4.4A.6R, our recommendation must be the most suitable product from the whole market. We weigh your income, plans, risk tolerance, need for flexibility, and any vulnerabilities before we recommend.

03

Clear fees and payment

For most residential cases, the lender pays us a procuration fee. A client fee of up to £300 applies only to complex advice where the mortgage is less than £200,000. We confirm any fee in writing before any chargeable work begins, and we only charge it on legal completion.

04

Ongoing review and monitoring

We monitor complaints, file reviews, customer feedback, service take-up, provider spread and outcomes for customers with characteristics of vulnerability. If we spot poor value or foreseeable harm, we investigate, record it and take remedial action.

Assessment process

How we assess fair value

We treat fair value as a six-step cycle. Each step has a clear input, a clear question, and a clear record. The result is a repeatable, evidence-based test we apply to our advice, the products we recommend, and the service you receive.

01
Step 01

Define the service and the customer need

We start by confirming the advice you need — residential or buy-to-let mortgage, remortgage, second charge, bridging, or protection — and the circumstances that matter to you, such as flexibility, repayment certainty, speed, or help with a complex application.

Input

Your objectives, circumstances and any characteristics of vulnerability.

Test

Do we understand what a good outcome looks like for you?

02
Step 02

Search the whole market and compare total cost

We research products from across the market, not a restricted panel. We compare interest rates, arrangement fees, valuation costs, cashback, early-repayment charges and the follow-on rate so the recommendation is based on total cost over the deal period, not the lowest headline rate.

Input

Products from across the whole market.

Test

Which product has the lowest total cost over the deal period?

03
Step 03

Test suitability and match the target market

We check that the product fits our target market and your needs. We look at your income, affordability, future plans, attitude to risk and any characteristics of vulnerability, then record why the chosen product is the most suitable from those available.

Input

Your income, affordability, plans, risk tolerance and vulnerabilities.

Test

Is this the most suitable product from those available?

04
Step 04

Add the cost of advice and any charges

For most residential mortgage cases the lender pays us a procuration fee on completion. A client fee of up to £300 applies only to complex advice where the mortgage is less than £200,000. We set this out in writing before chargeable work begins, and it is only payable on legal completion.

Input

Lender procuration fee and any applicable client fee.

Test

Does the total package — advice + product — still deliver fair value?

05
Step 05

Check for foreseeable harm and exit costs

We stress-test the recommendation against interest-rate rises, changes in income or employment, and early-exit scenarios. If a product could cause foreseeable harm, we record the risk and explain why it still represents fair value, or we recommend a different solution.

Input

Stress scenarios: rate rises, income changes, early exit.

Test

Could this recommendation cause foreseeable harm?

06
Step 06

Review against management information and customer outcomes

We monitor complaints, file reviews, customer feedback, completion times, provider spread and outcomes for customers with characteristics of vulnerability. If the evidence suggests poor value or harm, we investigate and take remedial action.

Input

Complaints, file reviews, feedback, provider spread and completion times.

Test

Did the outcome deliver value, and what do we do if it did not?

Fees and scope

What you pay, and who we advise

Our fees and how we’re paid

For most residential mortgage cases we are paid a procuration fee by the lender on completion. A client fee of up to £300 applies only to complex advice where the mortgage is less than £200,000. It is agreed and confirmed in writing before chargeable work begins and is payable only on legal completion. We define complex advice as an instruction containing any element of adverse credit, unsecured debt consolidation, residential interest-only, lending into retirement or power of attorney. For insurance business, we usually receive commission from the provider on the sale of a policy. We will always tell you the actual amount before you commit, and you can request the exact sum in cash terms at any time.

Target market

Our target market includes first-time buyers, home movers, remortgage customers, further advances, second-charge mortgages, consumer buy-to-let (CBTL), bridging finance and clients seeking pure protection or general insurance advice. Our service is designed for UK-resident individuals (aged 18+) and eligible UK-registered limited companies seeking advice relating to UK property. It is not suitable for execution-only clients who do not want a personal recommendation, for minors, for individuals who are unable to evidence the sustainability of their income, for complex mortgage advice where the borrowing is less than £75,000, for non-UK residents whose circumstances fall outside mainstream and specialist lender criteria, or for lending secured on non-UK property. We consider individual needs, including characteristics of vulnerability, and make reasonable adjustments so customers can understand and use our service.

Governance

How we keep the assessment up to date

Our fair-value assessment is reviewed at least annually and sooner if there is a material change to products, pricing, services, customer outcomes or regulatory requirements. The review is owned by Geoffrey Arnold, our Compliance Officer, and is informed by management information covering fees, commissions, file quality, complaints, vulnerable customer outcomes, and lender panel spread. Where the assessment identifies a risk of poor value or foreseeable harm, we record the finding and the action taken.

Fees

FAQ about our fee structure

Clear answers to how we charge, what is included, when a fee applies, and how we keep you informed before any chargeable work begins.

Are there any fees for your mortgage advice?

For most residential cases, advice is paid by the lender procuration fee. A client fee of up to £300 applies only to complex advice where the mortgage is less than £200,000 and is payable on legal completion. We define complex advice as an instruction containing any element of adverse credit, unsecured debt consolidation, residential interest-only, lending into retirement or power of attorney. This will be confirmed in writing before any chargeable work begins.

What is included in the advice fee?

Your initial fact-finding call (45–60 minutes) is free and no-obligation. If you proceed, we cover the full advice process: understanding your circumstances, searching the whole market, presenting a fully costed recommendation, handling lender paperwork, and supporting the case through to completion.

Will I be told about any fees before I have to pay?

Yes. Any chargeable work will be confirmed in writing before it begins. You will know the exact amount of any client fee, when it is payable, and what it covers before you commit.

When would a client fee apply?

A client fee of up to £300 applies only to complex advice where the mortgage is less than £200,000 and is payable on legal completion. We define complex advice as an instruction containing any element of adverse credit, unsecured debt consolidation, residential interest-only, lending into retirement or power of attorney. We will explain whether this applies to you, set out the exact amount, and confirm it in writing before any chargeable work begins.

Are fees different for buy-to-let or protection advice?

The same mortgage client-fee structure applies to residential and buy-to-let mortgage advice. A fee of up to £300 applies only to complex mortgage advice where the mortgage is less than £200,000 and is payable on legal completion. For protection and general insurance, we normally receive commission from the provider and do not charge that mortgage client fee. Any amount payable by you is confirmed in writing before chargeable work begins. This is set out in full in our Fair Value page.

At a glance

Policy owner
Geoffrey Arnold, Compliance Officer (SMF16)
Complaints Officer
Ian Arnold
Scope
Mortgage, pure protection and general insurance advice
Client fee
Up to £300, only for complex mortgage advice below £200,000
Assessment date
04 August 2026
Last reviewed
26 July 2026, and at least every 12 months

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.