The Intermediary Mortgage Lenders Association (IMLA) has welcomed the FCA’s feedback statement and roadmap on DP25/2, describing it as a positive and constructive step towards widening access to sustainable home ownership, while maintaining high standards of responsible lending.
IMLA says it is encouraged by the tone of the statement, which reflects the wide range of views expressed by respondents and shows a clear determination to find the right balance between flexibility and caution.
In particular, the association welcomed the The focus of FCA on advice and its intention to explore changes that could better support first-time buyers and borrowers who have historically found it more difficult to access the mortgage market.
The association also welcomed the FCA’s recognition that traditional approaches to affordability do not always reflect how people actually manage their finances over time. The move towards a more nuanced ‘form of affordability’, especially in the context of late-life borrowing, variable incomes and economic uncertainty, is seen as a sensible evolution that places advice at the heart of good customer outcomes.
IMLA research underlines that the market is well positioned to support this direction of travel. The New Normal 2026/27 report shows that mortgage arrears are expected to continue to fall, lending remains resilient and around 87% of regulated mortgage loans are made through intermediaries, reinforcing the central role of advice in the market.
IMLA also noted that the FCA’s focus on disadvantaged groups builds on long-standing discussions in the sector. The report ‘Why Subordinated Loans Shouldn’t Exclude Themselves’ (November 2021) highlighted that many households who could sustainably afford a mortgage still believed home ownership was out of reach. IMLA believes that greater flexibility, combined with high-quality advice, can help close this trust gap.
Commenting, IMLA Executive Director Kate Davies said: “This is a thoughtful and encouraging roadmap from the FCA. It is clear that they have listened carefully to the responses to the discussion paper and are genuinely trying to find the right balance between making some rules less rigid and continuing to support responsible lending.”
She concluded: “We’ve been talking for some time about the need to better serve groups who assume a mortgage isn’t for them, when in reality it could be. With good advice and a more realistic approach to affordability, the market is in a strong position to help more people explore their options.”

