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Showing posts from July, 2026

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...

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 ...