2019 FCA Mortgage Study and Specialist Brokers: A mortgage market can offer thousands of products and still make choice difficult.
In March 2019, the Financial Conduct Authority published its final Mortgages Market Study. The study examined how effectively consumers could identify and select suitable first-charge residential mortgages.
Its findings were especially relevant to specialist mortgage brokers. Complex cases often depend on more than the headline interest rate. Income structure, credit history, property type and lender policy can all affect whether an application fits.
At a Glance
The FCA found that the mortgage market worked well in many respects. However, some borrowers could have obtained a cheaper suitable mortgage.
For specialist brokers, the report reinforced five practical points:
- Price should not be considered without eligibility.
- Lender criteria must be interpreted carefully.
- Product choice should reflect the applicant’s circumstances.
- Mortgage switching may not be straightforward for every borrower.
- Adviser knowledge remains important when a case falls outside standard criteria.
What did the FCA Mortgage Market Study examine?
The FCA Mortgages Market Study focused mainly on first-charge residential mortgages.
It considered whether:
- consumers could make effective mortgage choices;
- suitable products were easy to identify;
- commercial arrangements affected recommendations;
- borrowers could switch to more suitable products;
- changes could improve mortgage comparison and advice.
The study did not directly assess the full specialist finance market. It did not centre on commercial mortgages, second charges or most buy-to-let lending.
However, its findings raised questions that also matter when brokers assess more complex applications.
Liz Syms on FCA’s Mortgage Market Study
A Resilience-Focused Perspective for Specialist Mortgage Brokers. Liz Syms, CEO of Connect for Intermediaries, shares a specialist broker’s perspective on the Financial Conduct Authority’s (FCA) final Mortgage Market Study, a pivotal review with implications for adviser-led resilience planning.
The FCA’s comprehensive report reviews the first-charge residential mortgage market and confirms that, while the market functions well in many areas, it still exhibits key weaknesses. These shortcomings, particularly an overemphasis on price at the expense of suitability, have left some consumers underserved and financially exposed.
The final findings call for improvements in mortgage and financial resilience, where brokers and advisers play a vital role. Liz highlights that shifting the focus from cost to value-added services, such as income protection and financial planning, can better safeguard clients during income shocks and economic uncertainty.
These insights align with advisers’ efforts to strengthen client resilience strategies by integrating protection tools and broader planning into everyday mortgage advice.
📌 For deeper support tools, visit our Adviser Services page.
📌 Explore our Protection and Insuranceguide to learn how to build long-term security for clients.
Why price alone could not determine suitability
A low advertised rate is only useful when the applicant meets the lender’s criteria.
Specialist cases may involve:
- self-employed or contractor income;
- recent adverse credit;
- several sources of income;
- portfolio landlord exposure;
- unusual property construction;
- short ownership periods;
- complex deposit arrangements;
- applicants approaching or beyond standard retirement ages.
Two products may appear similar during an online search. Yet their underwriting policies can produce very different outcomes.
The practical role of the specialist broker is therefore not simply to locate a rate. It is to establish which lenders may accept the applicant, property and proposed transaction.
Lender criteria were part of the real comparison
The FCA study highlighted the importance of helping borrowers compare suitable mortgages more effectively.
For specialist brokers, an effective comparison required more than a product table. It involved reviewing the rules behind each product.
This could include:
- accepted income evidence;
- affordability calculations;
- credit-scoring requirements;
- maximum loan-to-income limits;
- property restrictions;
- deposit sources;
- loan purpose;
- repayment strategy;
- lender exposure limits.
The visible product was only the final part of the decision. The underlying criteria determined whether that product was realistically available.
This principle continues to sit at the centre of specialist lending support for mortgage brokers.
Why wider lender access mattered
Specialist lending was not a single product category. Different lenders accepted different risks, income types and property structures.
A restricted panel could reduce the number of realistic routes available to an adviser. A broader panel could support a more complete assessment, although panel size alone did not guarantee suitability.
Brokers also needed to understand:
- which lenders operated in the relevant market;
- how each lender assessed the case;
- when manual underwriting was available;
- what evidence the lender required;
- whether the proposed application met the lender’s policy.
A mortgage network for advisers could support this work through lender access, criteria guidance, compliance oversight and case placement support.
Mortgage switching was not equally simple for everyone
The FCA study also considered borrowers who could not switch, or who did not switch, to another mortgage.
A borrower might remain with an existing lender because of:
- changed affordability;
- reduced income;
- a weaker credit profile;
- increased property exposure;
- age or term restrictions;
- insufficient equity;
- early repayment charges;
- limited access to alternative lenders.
Therefore, remaining on an existing mortgage did not always indicate poor financial judgement. Sometimes the available criteria restricted the borrower’s practical choices.
Specialist brokers needed to identify the difference between customer inaction and genuine lender restrictions.
What the study meant for mortgage networks
The report reinforced the need for a structured advice process.
For an appointed representative handling specialist cases, the network’s role could include:
- maintaining appropriate lender relationships;
- providing technical case support;
- checking advice standards;
- supporting compliant research;
- delivering lender and regulatory training;
- reviewing files and supporting good customer outcomes.
Technology could organise information, but it could not remove the need for judgement. A criteria result still needed to be tested against the complete client circumstances.
This is why mortgage broker training and development remained important as products and lending policies changed.
The practical lesson for specialist brokers
The 2019 FCA study showed that effective mortgage choice depended on both information and interpretation.
For straightforward applicants, a comparison tool might narrow the market quickly. For complex applicants, suitability often depended on details that could not be understood from the rate alone.
A specialist broker added value by connecting three elements:
- the client’s complete circumstances;
- the lender’s detailed criteria;
- the evidence required for a suitable application.
The philosophical lesson was simple. More products did not automatically create clearer choices. Clarity came from understanding which choices were real.
Finding a specialist mortgage adviser
Consumers looking for advice can use the Connect Experts mortgage adviser directory to search by mortgage expertise, location and other practical preferences.
Connect Experts is a directory and matching platform. Advice is provided by the adviser or firm selected by the customer.
Speak to Connect Network
Connect supports mortgage advisers across mainstream and specialist lending.
Our network provides lender access, compliance guidance, training, technology and practical case support for appointed representatives.
Join Connect Network to learn more about the support available to experienced mortgage advisers.
Frequently asked questions
What was the FCA Mortgages Market Study?
It was an FCA review of the UK first-charge residential mortgage market. The final report was published in March 2019.
Did the study focus on specialist mortgages?
Not directly. Its main focus was first-charge residential mortgages. However, its findings about consumer choice, suitability and switching were relevant to specialist mortgage advice.
Why are specialist mortgage brokers useful?
They may help where an application involves non-standard income, adverse credit, complex property, portfolio lending or other detailed lender criteria.
Is the lowest mortgage rate always the most suitable?
No. The applicant must meet the lender’s affordability, credit, property and eligibility requirements. Fees, term, features and overall cost must also be considered.
What support can a mortgage network provide?
A network may provide lender access, compliance guidance, training, technology and case placement support. The exact services depend on the network agreement.