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UK Finance represents around 300 firms in the UK providing credit, banking, markets and payment-related services. The new organisation takes on most of the activities previously carried out by the Asset Based Finance Association, the British Bankers’ Association, the Council of Mortgage Lenders, Financial Fraud Action UK, Payments UK and the UK Cards Association. Please go to for wider content and updates from UK Finance.

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  4. FCA Quarterly Consultation Paper No. 14: CP16/21

FCA Quarterly Consultation Paper No. 14: CP16/21

Last updated: 13 Sep 2016

Consulting body:
Financial Conduct Authority
Period of consultation:
Runs from 13 September 2016 to 2 November 2016
CML action:
Response submitted

The Financial Conduct Authority (FCA) has issued a consultation paper, proposing to update the equity release rules in Mortgage:Conduct of Business Rules (MCOB), to facilitate the availability of lifetime mortgages where the consumer can choose to switch to interest roll-up.

There will also be consequential changes to SUP for the reporting of Product Sales Data. 

CML response

Whilst we broadly support the FCA proposals to allow lifetime mortgage consumers to choose to switch to interest roll-up, we should stress that the borrower must be made fully aware of the risks involved if they choose to do so.

In the document below we provide our response to the questions posed by the FCA in the consultation:

  • 'Do you agree with our proposed approach to lifetime mortgages that allow the consumer to choose to switch to interest roll-up?'
  • 'Do you agree with our proposal for how firms should determine the length of term when illustrating equity release products?'

Download the full CML response below.