The FCA has published its Regulatory Priorities report for the mortgages sector, setting out where it will focus supervisory attention over the year ahead. Covering mortgage and home finance lenders, administrators and intermediaries, the report is intended to give boards and senior leaders a clearer, more joined‑up view of regulatory expectations, replacing multiple portfolio letters with a single point of reference.
For the mortgage sector, the update comes at a time of relative resilience. For instance, arrears have remained low despite prolonged interest rate pressure. But the FCA is clear that maintaining stability is only part of the picture. Firms are expected to continue adapting to changing consumer needs and to demonstrate, in practice, how good outcomes are being delivered across the customer journey, with the Consumer Duty firmly embedded.
Adapting to a changing mortgage landscape
A recurring theme throughout the report is the FCA’s recognition that the mortgage market has evolved. Consumers are entering the market later, borrowing over longer periods and increasingly, managing mortgage commitments alongside other complex financial pressures into later life.
The FCA’s Mortgage Rule Review is central to this agenda. It is intended to ensure that the regulatory framework supports innovation and access while preserving responsible lending and appropriate consumer protections.
The FCA makes it clear that firms are expected to engage actively with this work, including consultations and focused market studies. This places an emphasis not just on policy awareness, but on firms’ ability to translate regulatory direction into workable processes, training and controls across frontline and operational teams.
Responsible lending and supporting customers in difficulty
Responsible lending remains a core priority. The FCA highlights affordability assessment as an area of ongoing focus, particularly as lending approaches evolve or access is broadened.
The expectation is not simply that firms comply with rules, but that affordability approaches are kept under review and continue to deliver good outcomes as market conditions and customer profiles change. This links to operational implications, particularly for teams responsible for assessments, oversight and quality assurance.
The report also reiterates the importance of supporting borrowers in financial difficulty. Firms are expected to provide timely, appropriate forbearance and to evidence how support frameworks operate in practice. As economic pressures persist, this is likely to place sustained demand on customer‑facing teams, collections functions and oversight structures.
Second charge lending is explicitly referenced, with firms expected to reflect on supervisory findings and consider whether their affordability and expenditure assessments remain fit for purpose.
Advice quality and delivering consistency at scale
Advice quality is the third headline priority in the report. The FCA’s focus here extends beyond individual advice interactions to how advice quality is managed, monitored and assured across firms.
Mortgage firms are expected to ensure that advisers recommend suitable products, including when customer needs are more complex, while maintaining robust record-keeping and quality assurance arrangements. Importantly, this is framed through the lens of outcomes, not just process compliance.
For many firms, delivering this consistently requires sufficient capacity, experienced resource and well‑designed assurance approaches – particularly when volumes increase or change initiatives are underway.
Governance, resilience and operational readiness
Beyond the headline priorities, the report draws together several broader supervisory themes, including operational resilience, disorderly failure planning, appointed representative (AR) oversight, conflicts of interest and Senior Managers and Certification Regime (SMCR) accountability.
Taken together, these areas reinforce the FCA’s expectation that firms have the right people, governance and operational capability in place to respond quickly and proportionately to regulatory focus areas. As frameworks evolve and scrutiny increases, the ability to mobilise skilled resource and deliver change at pace becomes increasingly important.
Turning regulatory priorities into delivery
For boards and senior leaders, the Regulatory Priorities report evidences where the FCA’s attention will sit and the standard of delivery it expects. Firms that are able to scale teams, strengthen oversight and implement change efficiently will be better placed to respond confidently, particularly as initiatives such as the Mortgage Rule Review progress.
How Momenta supports mortgage firms
Momenta works with mortgage firms to strengthen operational capability and support high‑quality outcomes at scale. Through flexible, on‑demand resourcing, we help firms respond to regulatory priorities by providing experienced professionals to support affordability reviews, advice quality assurance, remediation activity and customer support functions – enabling firms to deliver confidently under sustained regulatory and operational pressure.
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