Not so long ago, learning about personal finance meant picking up a textbook, reading the weekend money pages or booking an appointment with an adviser.
Today, consumers can ask an AI assistant virtually anything from pension tax relief and mortgage rates to Budget announcements and investment strategies, and have answers arrive in seconds. That shift is remarkable, and we shouldn’t lose sight that we have moved from an age of information scarcity to one of information abundance.
But there is a problem.
As AI increasingly becomes the front door to financial information, who decides which answers consumers see and, more importantly, which they don't?
For all its promise, AI is not an impartial guide. It can get things wrong. It can present incomplete information and often, even the people building these systems cannot fully explain why a particular recommendation, answer or product has been surfaced.
That matters when consumers are making financial decisions that could shape the rest of their lives.
An AI model is only as good as the information it is given, and unless consumers provide detailed context about their finances, goals and personal circumstances, there is no guarantee the response they receive will be relevant, appropriate or complete. Even then, AI cannot replicate the judgement of an experienced adviser - it cannot detect hesitation, uncover hidden objectives or spot opportunities that a consumer may not even know exist.
That creates a particular challenge for the later life lending sector, given our market already faces a significant awareness problem. Too many consumers reach retirement without understanding the full range of borrowing options available to them, and the danger is that AI doesn't solve that problem - it reinforces it.
Consider the numbers - the over-55 market accounts for around £60bn of annual purchase, remortgage, product transfer and further advance lending, yet equity release lending totalled just £2.6bn last year. That disparity raises an obvious question: how many customers are never being presented with later life lending solutions in the first place?
The distribution figures tell a similar story, given there are around 35,000 mortgage brokers in the UK with mortgage permissions, yet only around 6,000 hold permissions to advise on later life lending products.
In other words, most brokers are unable to advise on a significant part of the later life lending market. Now imagine that same visibility problem being replicated, and potentially amplified, by AI.
The FCA is already examining the future of later life lending through its Later Life Mortgages Market Study. At the same time, the regulator's Mills Review has highlighted the rapid growth of AI adoption, with around one in four UK adults already trusting general-purpose AI tools such as ChatGPT, Claude and Gemini for financial advice.
That should be a wake-up call, because if consumers increasingly rely on AI to navigate their financial lives, these platforms will become powerful gatekeepers of information, influencing which products are considered, which solutions are dismissed and which conversations never happen at all.
The FCA itself has warned of a future in which consumers "see only the options selected by an AI system" without understanding why those options were chosen. That is not simply a technology issue, but a consumer choice issue.
The financial services sector has spent decades expanding access to information, improving transparency and giving consumers more options. We must be careful that AI does not inadvertently reverse that progress by narrowing the range of solutions people are exposed to.
Let's be clear: this is not an argument against AI, which has the potential to transform financial services for the better by making information more accessible, reduce friction and deliver more personalised experiences than ever before. But innovation should not come at the expense of visibility, or at the expense of true informed decision making.
The Mills Review has recommended that the FCA consider a review of the regulatory perimeter within the next three to six months, examining how consumers are using AI and the potential risks of harm. Ultimately, that conversation can’t focus solely on accuracy or bias, but must also address discoverability.
If AI systems fail to surface the full range of suitable options available to consumers, entire sectors risk being pushed into the shadows. Not because those products are inappropriate, but because they were never included in the algorithm's shortlist in the first place – and the consequences for later life customers could be profound.
The later life lending advice gap is already too large, and consequently we cannot allow an AI visibility gap to emerge on top of it. The FCA's Later Life Mortgages Market Study is rightly exploring how products such as lifetime mortgages can play a greater role in funding retirement. But as AI takes on a growing role in financial decision-making, regulators, lenders and technology firms must ask a more fundamental question:
Will consumers still see all of the options available to them, or only the options an algorithm chooses to show?
If we fail to answer that question now, later life lending risks becoming invisible in the very channels consumers increasingly rely on for guidance - and once a product disappears from an AI-generated conversation, it becomes much harder to bring it back.
