Air sets out Consumer Duty blueprint for later life lending advice

A new report from Air argues that modelling housing equity alongside pensions and investments is essential to meeting consumer duty expectations in later life lending.

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Air has published a new report designed to help advisers evidence later life lending decisions under Consumer Duty by modelling outcomes — including inheritance implications — so that trade-offs are clear and documented.

The report, produced with Technical Connection and Ad Lucem, places regulatory alignment at the centre of later life advice. It argues that compliance is strengthened where advisers can demonstrate that all relevant assets and options have been considered, rather than defaulting to a single route.

THE HOME IN THE PLAN

Titled The home belongs in the plan – Why later life lending is essential for client centred advice, the report examines the trade-offs involved in using housing equity and the types of clients it may support.

Air said advisers are facing increasing pressure from clients seeking support “now, not later”, particularly where family assistance or liquidity needs are immediate.

The paper sets out a framework intended to help advisers evidence their decision-making and align recommendations with Consumer Duty, while strengthening file documentation.

It argues that effective financial planning requires sequencing assets and determining which to use and why. However, it cautions that advice cannot be delivered solely through spreadsheet modelling, noting that later life lending decisions are often driven by personal circumstances and individual aspirations.

The report also highlights the need for borrowers and close family members to understand the practical, legal and financial implications of releasing equity. Particular emphasis is placed on the role of interest rates and whether repayments are made, given the centrality of compound interest to the long-term outcome.

At the same time, Air maintains that modelling a range of options — including pensions, investments, downsizing and housing equity — provides a consistent and auditable framework for advisers.

This, it suggests, can help align family expectations and demonstrate fairness through clear communication.

Tony Wickenden, founder and managing director of Technical Connection, said: “Later life lending isn’t for everyone — but for the right clients it can support outcomes like earlier family help, improved liquidity, or greater retirement resilience, when the trade-offs are understood and recorded.

“While the desire to achieve a specific outcome, such as helping with a property purchase, can be very strong, it is essential that all parties fully understand the longer-term financial implications.

“Later life lending can be a valuable planning tool when used deliberately with clear guardrails enabling advisers to deliver Consumer Duty-safe decision making processes that families can understand and live with.”

Will Hale, chief executive of Air, said: “Clients need advice that brings every part of their balance sheet into view, including the asset that represents a significant percentage of overall wealth for many which is their home.

“At Air, our goal is to equip advisers with the insight and tools they need to establish productive referral relationships where appropriate and to deliver confident, client centred advice in a fast-moving environment.”

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