FCA Regulated • MCOB Compliance

Mortgage Broker Compliance Consultants

Comprehensive FCA authorisation and MCOB compliance support for mortgage brokers and advisers. Whether you're providing advice or arranging mortgages, we help you navigate regulatory requirements and build a compliant mortgage business.

Mortgage Advisory & Arrangement Services

Understanding the difference between advisory and non-advisory mortgage services

Advisory Services

Providing mortgage recommendations and advice

When you make a personal recommendation to a customer about a mortgage

Key Features:

  • Personal mortgage recommendations
  • Suitability assessments required
  • Whole of market vs restricted advice
  • Enhanced disclosure requirements
  • Ongoing suitability obligations

Regulatory Requirements:

  • Qualified mortgage advisers (CeMAP or equivalent)
  • Detailed suitability reports
  • Comprehensive fact-finding
  • Product research and selection
  • Consumer Duty fair value assessments

Non-Advisory Services

Arranging mortgages without personal recommendations

When you arrange mortgages but don't provide personal recommendations

Key Features:

  • Mortgage arrangement services
  • Application submission support
  • Product information provision
  • Limited disclosure requirements
  • No suitability assessment needed

Regulatory Requirements:

  • Clear disclosure of non-advisory status
  • Product information provision
  • Application processing capabilities
  • Customer understanding documentation
  • Appropriate staff competence

Managing Your Mortgage Permissions

Understanding and maintaining the right FCA permissions for your business model

Mortgage Types

Different mortgage permissions available

  • Residential mortgages
  • Buy-to-let mortgages
  • Equity release (lifetime mortgages)
  • Home reversion plans
  • Second charge mortgages

Permission Scope

Defining your business activities

  • Advising on regulated mortgages
  • Arranging regulated mortgages
  • Whole of market vs panel
  • Direct authorization vs appointed representative
  • Additional lending permissions

Ongoing Compliance

Maintaining your permissions

  • Variation of permissions applications
  • Threshold conditions maintenance
  • Regulatory reporting obligations
  • Competence and qualification updates
  • Consumer Duty implementation

MCOB Compliance Requirements

Navigating the Mortgages and Home Finance: Conduct of Business sourcebook

Customer Documentation

Required disclosures and documentation

  • Initial disclosure documents
  • Services and fees disclosure
  • Mortgage illustrations (KFI)
  • Suitability reports (advisory)

Customer's Best Interests

Acting in the customer's best interests

  • Fair value assessments
  • Whole of market considerations
  • Remuneration disclosure
  • Conflict management

Responsible Lending

Affordability and creditworthiness

  • Affordability assessments
  • Income and expenditure verification
  • Credit checks and scoring
  • Vulnerable customer identification

Product Governance

Mortgage product oversight

  • Target market identification
  • Product distribution arrangements
  • Fair value monitoring
  • Product review processes

Advice Standards

Quality of mortgage advice

  • Comprehensive fact-finding
  • Suitability assessments
  • Product research and selection
  • Clear suitability reporting

Records & Monitoring

Ongoing compliance evidence

  • Customer file maintenance
  • Compliance monitoring programs
  • Quality assurance reviews
  • MI and reporting

How MEMA Supports Mortgage Brokers

End-to-end support from authorisation through ongoing compliance

FCA Authorisation

Complete application support for mortgage permissions

Includes:

  • Permission selection guidance
  • Business plan development
  • Application preparation and submission
  • FCA query management
  • Post-authorisation setup

MCOB Implementation

Embedding MCOB requirements into your processes

Includes:

  • Policy and procedure creation
  • Documentation templates
  • Compliance monitoring frameworks
  • Staff training programs
  • Quality assurance systems

Ongoing Advisory

Continuous regulatory support and guidance

Includes:

  • Regulatory change monitoring
  • Compliance health checks
  • Variation of permissions support
  • FCA correspondence assistance
  • Remediation project guidance

Essential Requirements for Mortgage Brokers

Critical compliance areas for mortgage broking businesses

Appropriate FCA permissions
Qualified mortgage advisers (CeMAP)
MCOB-compliant documentation
Consumer Duty implementation
Professional indemnity insurance
SM&CR compliance

Sectors We Support

This service is available for firms across these regulated sectors

What Mortgage Broker Compliance Involves

FCA compliance for mortgage brokers is governed principally by the Mortgage Conduct of Business sourcebook (MCOB), overlaid by Consumer Duty and the Senior Managers and Certification Regime. Here is what staying compliant involves in practice.

1. Advice, suitability and affordability

Most mortgage sales are advised, which means a personal recommendation that must be suitable for the customer's needs and circumstances under MCOB 4. Firms must assess affordability, evidence the basis for each recommendation, and keep suitability records that stand up to FCA review.

2. Disclosure and Consumer Duty

Customers must receive clear, timely disclosure, including the European Standardised Information Sheet (ESIS). Under Consumer Duty, firms also have to show that customers receive fair value and good outcomes, not simply that the MCOB process was followed. We help brokers evidence their fair value assessments and consumer-understanding obligations.

3. Governance, permissions and reporting

Mortgage firms must hold the right permissions, meet their SMCR obligations, run compliant financial promotions, handle complaints under DISP, and submit accurate regulatory returns. Our consultants build the compliance framework and provide ongoing oversight so these obligations are met continuously, not just at the point of authorisation.

Frequently Asked Questions

Common questions about mortgage broker compliance

Do I need to be FCA authorised to broker mortgages?
Yes. Arranging or advising on regulated mortgage contracts is a regulated activity, so mortgage brokers must be either directly authorised by the FCA or an appointed representative of a principal firm. Operating without the right permission is a criminal offence under section 19 FSMA. MEMA helps brokers choose between direct authorisation and appointed representative status, and prepares the application either way.
What is MCOB?
MCOB is the FCA's Mortgage Conduct of Business sourcebook, the rulebook governing how firms sell and administer regulated mortgages. It covers advice and suitability (MCOB 4), affordability and responsible lending, pre-sale disclosure including the ESIS, charges, and the treatment of customers in payment difficulty (MCOB 13). Mortgage brokers must be able to evidence compliance with MCOB across the full customer journey.
How has Consumer Duty changed mortgage broker compliance?
Consumer Duty raised the bar from following MCOB processes to demonstrating good customer outcomes. Mortgage brokers now have to evidence fair value, consumer understanding and appropriate support, not just that a suitability assessment was completed. In practice that means documented fair value assessments, clearer customer communications, and management information showing outcomes are monitored. Firms that treat MCOB as a tick-box exercise are the most exposed.
Can you provide ongoing compliance support for a mortgage brokerage?
Yes. Alongside FCA authorisation and MCOB implementation, MEMA provides ongoing compliance support for mortgage brokers: file reviews, financial promotion sign-off, complaints handling under DISP, regulatory reporting, and SM&CR administration. Retained support is cost-effective for smaller brokerages that face the same obligations as larger firms but cannot justify a full-time compliance hire.

Ready to Build Your Mortgage Broking Business?

Contact our mortgage broking specialists for expert FCA authorisation and MCOB compliance support

📞 Phone: 0330 133 0811

📧 Email: contact@memaconsultants.com