Consumer Duty Product Information Sheet: Later Life Lending product range

Help and support for intermediaries

This information is intended for Intermediaries use only and should not be provided to customers.

Our approach to meeting the products & Services Outcome and Price & Value Outcome – Information for distributors of the product. 

This summary document is being provided to you to fulfil our responsibilities under PRIN 2A.4.15R and PRIN 2A.3.12 R (2). It is designed to support you to comply with your responsibilities under PRIN 2A.3.16 R and PRIN 2A.4.16 R. Please note that you are ultimately responsible for meeting your obligations under ‘The Consumer Duty’.
 

We have assessed that:

  • Our Later Life Lending product range continues to meet the needs, characteristics, and objectives of customers in the identified target market.

  • The intended distribution strategy remains appropriate for the target market.

  • The product provides fair value to customers in the target market (i.e. the total benefits are proportionate to total costs.)

The products are designed to meet the needs of the target group, most notably the need for mortgage finance in retirement or that will take the borrower in to retirement. The product features and criteria are designed to support these needs.

  • Fixed and variable rate products

  • Free standard mortgage valuation

  • Family support options (subject to eligibility)

  • Do not credit score, manually underwrite

  • Mortgage term up to age 90

  • Products allow for some form of overpayments

  • Mortgage is portable

  • Interest only options

  • Retirement Interest Only (RIO) option

Full eligibility criteria can be accessed here.  

This target market assessment matrix segments the target customers for the product, recognising their different needs to enable you to tailor the services you provide when you distribute the product.

Customer circumstancesDistribution strategyCustomer needs and objectives
Borrower taking mortgage term past
expected retirement date
  • Available through direct and Intermediary* channels.
  • Applications can be through advised sale and execution-only.
  • Access to mortgage finance both before and after retirement
  • Choice of fixed or variable products for defined periods
  • To repay the capital by the end of the mortgage term
  • Choice of interest only options
Borrower taking mortgage finance when already retired
  • Available through direct and Intermediary* channels.
  • Applications can be through advised sale and execution-only.
  • Access to mortgage finance after retirement
  • Choice of fixed or variable products for defined periods
  • Choice of Retirement Interest Only (RIO) or defined term
  • To repay the capital by the end of the mortgage term
  • Choice of interest only options
*Intermediary distribution through:

  • Networks and their appointed representatives

  • Mortgage clubs

  • Directly Authorised mortgage intermediaries

All Intermediaries or their network/club must be registered with us

The product is not designed for customers who:

  • Are reliant upon earned income past age 70

  • Are aged over 80 at application

  • Customers looking for RIO but not yet retired

  • Are credit impaired

  • Do not meet our lending or property criteria

The product is designed for customers who are looking to have mortgage finance into retirement, which is likely to include some customers with characteristics of vulnerability or who will experience vulnerability over time.

Older customers are likely to have a reducing comprehension of mortgages or the mortgage market. Therefore, they may require additional advice and support to ensure they understand the information being presented to them and the implications of the arrangement they are entering into to reduce the risk of harm occurring.

We considered the needs, characteristics, and objectives of customers with characteristics of vulnerability at all stages of the design process for this product to ensure the product meets their needs.

We have also reviewed the outcomes of the product to assess whether it meets the identified needs, characteristics, and objectives of the target market, including customers in the target market who have characteristics of vulnerability.

We have in place a framework to achieve good outcomes for vulnerable customers, which includes:

  • Where the borrower is 70 or more at the start of the mortgage contract, it is strongly recommended that the borrowers obtain independent legal advice before entering into the transaction – this will be documented on the mortgage offer. A certificate from a solicitor confirming they have received such advice must be received prior to completion, where relevant.
  • Education and training for our staff to ensure they have the appropriate skills and experience to recognise and respond to the needs of vulnerable customers.
  • Suitable customer service provision and communications.
  • Flexible policies, where appropriate, to support vulnerable members
  • Monitoring to ensure we continue to meet and respond to the needs of customers with characteristics of vulnerability.

Intermediaries should continue to comply with your obligations to ensure that you treat customers in vulnerable circumstances fairly.

Please contact us if you need any further information about how we support the needs of all our customers in relation to the Product.

We have developed an assessment process which evaluates several aspects of our business to determine the value of our mortgage product. This analysis is used to ascertain whether the product delivers fair value for customers.

The outcomes of the assessment process are in line with a Board approved fair value framework, allowing for challenge and further investigation before we sign-off the outcomes and share the summary of our assessment with you.

BenefitsPriceCostsLimitations
The range of features that the product provides, the quality of the product, the level of customer service that is provided and any other features that the product may offer.The interest rates, fees and charges customers pay for the product, comparable market rates, advice fees paid to intermediaries and non-financial costs associated with operating the product. The cost of funding the product and any other reductions in costs to the customer made possible by economies of scale.Any limitations on the scope and service we provide or the features of the product.

Results of our assessment

Our assessment concluded that the product continues to deliver fair value for customers in the target market for the product.

Click here to download this Consumer Duty Product Information Sheet PDF