The Intermediary Mortgage Lenders Association (IMLA) has described the Financial Conduct Authority’s (FCA’s) Feedback Statement and roadmap on DP25/2 as a positive step towards widening access to sustainable homeownership, while maintaining robust lending standards.
The association said it was encouraged by the tone of the Statement, which reflects the breadth of views submitted by respondents and signals a clear intent to balance greater flexibility with prudence.
IMLA particularly welcomed the FCA’s focus on advice and its intention to explore changes that could better support first-time buyers and borrowers who have traditionally found it harder to access the mortgage market.
IMLA also welcomed the regulator’s recognition that traditional affordability assessments do not always reflect how households manage their finances over time.
A move towards a more nuanced ‘shape of affordability’, especially in the context of later life borrowing, variable incomes and wider economic uncertainty, was described as a sensible evolution that places advice at the centre of good customer outcomes.
IMLA said its own research suggests the market is well placed to support this direction of travel. Its New Normal 2026/27 report shows mortgage arrears are projected to continue falling, lending remains resilient and around 87% of regulated mortgage lending is conducted through intermediaries, underlining the central role of advice.
The association also noted that the FCA’s focus on underserved groups builds on long-standing industry debate. Its report, Why underserved borrowers should not rule themselves out, published in November 2021, highlighted that many households who could sustainably afford a mortgage nevertheless believe homeownership is beyond their reach.
IMLA believes that greater flexibility, combined with high-quality advice, could help address this confidence gap.
Kate Davies, executive director of IMLA, said: “This is a thoughtful and encouraging roadmap from the FCA. It’s clear they have listened carefully to the responses to the discussion paper and are genuinely seeking to strike the right balance between making some rules less rigid while continuing to support responsible lending.
“We’ve been talking for some time about the need to better serve groups who may assume a mortgage isn’t for them, when in fact 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.
“As we head towards the end of the year, it’s a welcome reminder that there are reasons to be positive about the mortgage market — and a good moment to encourage more people to speak to an adviser and see what might be possible.”
IMLA said it looks forward to engaging constructively with the FCA as further consultations emerge over the coming months and into 2026. With Christmas approaching, the association added that helping more people feel confident about their housing options would be a welcome boost for borrowers and the wider market heading into the new year.




