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Product transfer season is coming: is your pipeline built for the volume?

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  Before writing this, it is worth being upfront about one thing. Nobody publishes a month by month breakdown of exactly when fixed rate mortgages come to an end. A Freedom of Information request asking for precisely that figure was turned down in 2023 because the data simply does not exist in that form anywhere in government, and UK Finance would charge to produce it. So there is no clean answer to which specific month counts as peak season this year. What there is, is a much more useful set of numbers about scale, timing mechanics, and where the volume actually ends up going, and that turns out to matter more than the calendar does. The scale is not in question UK Finance estimates around 1.8 million fixed rate mortgages are due to expire in 2026, up from 1.6 million in 2025. Product transfers are forecast to reach £261 billion this year, alongside a further £77 billion in external remortgaging, a 10 per cent rise on 2025. Product transfer activity does not appear in official mea...
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What happens when AI gets an affordability calculation wrong and who is liable

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  On 6 July 2026, the FCA published the Mills Review, its assessment of how artificial intelligence will reshape retail financial services by 2030. It opens with almost exactly this question. When an AI system arranges a customer's mortgage, moves their savings, or recommends a pension, who answers if it goes wrong. For a mortgage business, that is not an abstract question about the future. It is a question about what happens the day an affordability tool gets a case wrong, a customer is either approved for something they cannot sustainably repay or declined for something they could have afforded, and somebody has to explain what happened. The short answer, and the one the FCA has now restated twice this year in different forms, is that the answer has not changed. The tool does not carry the liability. The firm does. The regulator's position is not new, it is just being said more plainly The FCA has never built a separate rulebook for AI, and it has said clearly it does not int...
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Consumer Duty audits are catching brokers out, what a defensible file actually looks like

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  A broker can walk into a file review feeling confident and still walk out with a list of findings. That has been happening more often since the Financial Conduct Authority told mortgage intermediaries, in a portfolio letter sent to chief executives in January 2025, that embedding the Consumer Duty properly would be its main supervisory focus for the following two years. Eighteen months on, the regulator has published enough findings across enough sectors to make one thing clear. A file that looks compliant and a file that is defensible are not always the same document. The gap between the two is where most of the trouble sits. A file can have every box ticked, every disclosure attached, every signature in place, and still fail to explain itself when someone outside the firm actually reads it. That is the standard now being applied, and it is worth understanding exactly what it involves before it gets applied to yours. What the regulator has actually been finding The January 2025 ...
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The Loaded Premium Scandal: How a Quarter of the UK Protection Market Is Silently Overcharging Customers

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  Two commission models - one honest, one not There is a critical distinction in the UK protection insurance market that most customers will never hear about, because nobody in the distribution chain has any incentive to explain it to them. It is the distinction between enhanced commission and loaded premiums. Understanding the difference is essential, because one of these models works in the customer’s interest and the other works directly against it. The first model, enhanced commission is straightforward and, frankly, legitimate. Large mortgage clubs such as TMA and Paradigm distribute enormous volumes of protection business. Because they place thousands of policies per year with each insurer, they have the commercial leverage to negotiate enhanced commission rates for their member firms. An insurer might pay a standard indemnity commission of 200% of the annualised premium index (API) to a small directly authorised firm but offer 250% API through a major mortgage club. The crit...
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