The FCA’s Discussion Paper (DP25/2), which is a wide-reaching document looking at what the future of the mortgage market could, and perhaps, should look like, feels like a pivotal moment for the entire sector, particularly the later life lending market.
For a start, it recognises what many of us in the later life lending sector have known for some time: we are no longer on the periphery. The demand and requirement for later life lending solutions is becoming central to the future of mortgage advice, and that recognition alone marks real progress.
At more2life, we’re working on our formal response to the paper ahead of the September deadline, and while we’ll be covering all aspects, we will be focusing closely on the questions outlined in Chapter 3 which of course is dedicated to the later life lending market.
In two analysis pieces, I want to explore potential answers to the four questions the FCA ask in Chapter 3, starting with Questions 13 and 14. Because here’s the truth: we have an opportunity to create a joined-up, scalable and resilient later life lending market, but it’s going to need the right framework to support it.
Q13 asks whether more borrowers should be looking to later life lending to support their retirement. The answer is, of course, a resounding yes. The reasons are compelling.
Millions of homeowners over the age of 50 still have mortgage debt. Many are reaching the end of historically low fixed rate deals. According to UK Finance research, around 1.8 million fixed rate mortgages will mature this year. Some will move straight onto expensive SVRs - some are well over 7% - and for a growing cohort, a remortgage won’t be suitable or even possible.
This is the moment to engage. We’re encouraging all advisers to look at how many of these customers are over 55, what their LTVs look like, whether they wish (or are able) to keep on making repayments, whether their needs have changed since the last mortgage, whether they can now access a whole new range of later life lending products, and how they might benefit from them - not just to escape high SVRs, but to give them the flexibility they need for this stage of life.
This is also where the regulator’s questions align with what we’ve been saying for a while: later life lending is not just about individual financial outcomes, it supports wider economic goals. Unlocking housing wealth can help support retirement, freeing up expenditure for consumption elsewhere, and enabling intergenerational support. It’s a win-win and it’s encouraging to see the FCA’s DP recognise this in clear terms.
But to get the most from this market, we also need the right kind of product development and that’s where Question 14 becomes key. The regulator wants to hear what it can do to support innovation. Our view is simple: allow later life products to be treated like any other mortgage. Create a level playing field. Let innovation flourish in an environment that doesn’t silo later life lending away from the mainstream.
At more2life, we’ve been leading on product innovation - from hybrid models that evolve over time to solutions that provide more flexible drawdown and servicing options. To lower or even zero ERC products, to those that allow interest to be served and rates to be determined by the repayments customers commit to.
But innovation on its own isn’t enough. Advisers need to feel confident engaging with this space. They need access to technology and insight that supports them in making the right recommendations, quickly and efficiently.
That’s why we built ProView, our platform that gives advisers an early-stage underwriting view within 24 to 48 hours. It helps reduce uncertainty, improves time-to-decision, and gives advisers the confidence to progress cases or to know when a different route might be better. Combined with our brand refresh, which puts later life lending firmly at the centre of our proposition, we’re doing everything we can to support a future-ready market.
But we also need clarity from a regulatory perspective. We want to see guidance that encourages earlier consideration of later life options, not just when all other doors are closed. We’d welcome consistency in how qualifications are structured, and support for embedding later life lending across advice journeys, not as a separate service. That’s the kind of regulatory evolution that unlocks real scale.
The demand is growing. The FCA has acknowledged it. The market has the tools and expertise. Now it’s about working together – regulator, lenders, advisers, networks, etc – to build the framework that will deliver for the millions of homeowners who will need these solutions in the years ahead.
