Consumer Duty Mortgage

Fair value: mortgages

Supporting you to meet your Consumer Duty obligations when recommending mortgages.

To make it easy for you to demonstrate fair value on the mortgage products you recommend to your customers, we’ve collated all the information you’ll need in one place.


Demonstrating fair value

Consumer Duty requires you to demonstrate that you offer fair value to your customers.

To do this, you’ll need to assess your products and services in terms of the value these provide to your customers. You’ll also need to define who your target market is and, just as importantly, who it’s not. Part of this exercise will require you to assess total costs to the customer, including any ancillary costs associated with the product, as well as the cost of your services. This essentially is the fair value assessment which you will need to complete for your business.

Consider the following:

  • Who your services are aimed at
  • Who your services are not aimed at
  • The products you advise on
  • What it costs you to deliver your services and products
  • The benefits your services and products deliver to your customers

You will need to assess the products based on their target market and whether the lender has determined that the product features and benefits represent fair value.

That’s why, to help make this easier for you, we’ve collated all this information in one place.  

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PMS lets you demonstrate fair value with confidence

At PMS, we take the work out of demonstrating fair value for the mortgage products you recommend.

That’s because we only work with mortgage lenders who can demonstrate fair value, and we undertake ongoing monitoring to ensure our lender partners continue to meet the standards set by our fair value framework.

So when you recommend a mortgage through PMS, you can enjoy confidence that it meets the fair value requirements set by Consumer Duty.

Below is a more detailed explanation of how we assess our lender panel, which will help you in meeting your regulatory obligations. This also allows you more time to concentrate on the services you offer and the overarching assessments you need to complete to fulfil your Consumer Duty requirements.

PMS’ fair value framework

Mortgage: initial due diligence

At PMS, we have a comprehensive due diligence process in place, for all our lender partners.

Whenever we add a new lender to our offering, we conduct an overarching assessment to ensure the lender meets Consumer Duty requirements. As part of this, we look at our prospective partners’ fair value assessments, product offerings and stated target markets.

We exclusively work with mortgage lenders who meet or exceed our strict criteria in each of these areas.

Ongoing reviews

We review our mortgage offering on an annual basis, to ensure that it remains suitable and continues to meet regulatory requirements.

This continuous monitoring and oversight is there to ensure that our offering remains appropriate for your needs, and that it continues to offer fair value to your customers.

We also hold regular meetings with our lender partners to assess their products and performance, and to make sure we have all the appropriate information on the products offered through PMS. If you write mortgages through PMS, you’ll have access to this information via the links below.

Where product or fair value issues are identified, these are escalated internally, and formal remedial actions will be instigated. The progress will be monitored until these are appropriately completed. If we believe that a particular product or lender no longer offers fair value to customers, the product or lender will be considered for removal.

So when you recommend a mortgage through PMS, you can be confident that it will be consistent with the needs of the specified target market.

View lender fair value frameworks

Click the logos below for the following information from PMS’ lender partners:

  • Stated target market
  • Product characteristics, features and benefits
  • Consideration of the needs, characteristics and objectives of any customers who may potentially be vulnerable
  • Intended distribution strategy

Limited distribution Lenders

  • AIB
  • HSBC
  • TSB