Reviewing a client's wider finances at a remortgage
At each remortgage you gather the client's whole financial picture. How to read it for pension, savings, protection and estate gaps, and open the wider conversation without giving regulated advice.
At each remortgage you gather the client's whole financial picture. How to read it for pension, savings, protection and estate gaps, and open the wider conversation without giving regulated advice.
At a remortgage you look at the whole of a client’s finances, and remortgages come round on a regular schedule. To place it you gather their income, their outgoings, their existing debts, their savings, who depends on them and what has changed since the last deal. This amounts to a financial review every few years.
Like an MOT, a regular check catches problems before they become expensive. You can use the remortgage to check the client’s wider finances and open the conversation about them without giving advice you are not permitted to give.
Before a lender will offer, you assemble a full picture of the client’s finances. Current income and how it is earned, monthly commitments, credit and other debts, the value of the property, the equity in it, and often the savings behind it. You ask what has changed since the mortgage was last arranged, because the answer affects the case. By the time the remortgage is ready you are holding a current, verified snapshot of the client’s finances. You can read that snapshot for wealth needs as well as for the loan.
Two things make the remortgage a good moment. The first is timing. The client is already thinking about money, already answering questions about their finances, and already expecting you to look at their position, so raising the wider picture is part of the same conversation. The second is that it repeats. A remortgage comes round every few years, which gives the relationship a scheduled point at which to check whether anything needs attention, in the same way an MOT falls due whether or not anything is wrong.
The remortgage documents show what has changed, and changes create wealth needs:
All of this is in the fact-find you already hold.
Check the same snapshot against these questions:
You do not answer any of these. You note which ones the client has no answer to, which is within your permissions.
Everything on that checklist can be reached through questions you are entitled to ask as part of understanding the client’s position. Asking whether a client contributes to a pension, whether they have savings behind them, whether their protection has kept pace with their income, or whether anything has changed in their family is not regulated advice. It is the ordinary work of understanding someone’s finances well enough to advise on their mortgage. The regulatory line applies to what you do with the answer.
When the checklist turns up a gap, name it and offer an introduction, in one sentence, without recommending anything. Something close to: “While we are reviewing everything anyway, I have noticed there is no pension going in and some cash sitting idle. I do not advise on that myself, but I work with a regulated firm who do, and I can introduce you if it would help.” The sentence points to a need and offers an introduction. It does not tell the client to open a pension, move the cash or change anything, so it sits within your permissions, and it is all you need to do.
You can advise on the mortgage, and on the protection around it, because life cover, critical illness cover and income protection are within your permissions. You must not advise on pensions, investments or estate and tax planning. Gathering the picture and noticing the gaps are yours. The regulated advice on what to do about them is ours, given by Equity & General under our FCA authorisation (No. 474163). Reviewing the client’s wider finances at a remortgage needs no new permission and no compliance work for the advice, because E&G gives the advice.
Once the client agrees and the consent is recorded, the wider work moves to us. We contact the client, usually within a week, and the first meeting is a fact-find, free of charge, at which products are not discussed. We give the regulated advice, take on the administration and the responsibility, and keep the client informed throughout. You see the progress in the partner portal without chasing anyone. The mortgage stays yours, placed the way you place it now. As the client builds assets under management with us, you share in the value, and that income continues after the remortgage completes.
This needs no new process. You already gather the picture, so the only change is to read it for more than the loan and to add one question when a gap appears. Do it at every remortgage and each client gets a scheduled check on their whole financial position. Where there is nothing to address, it has taken one question. Where there is something to address, the client can begin an advice relationship with E&G that continues for years.
The check is not a separate review on the day. It means noticing the gaps in a picture you are already gathering for the mortgage, and adding one sentence when a gap appears. The wider review itself is ours, and it happens later, once the client has agreed to the introduction. Your part stays small and sits inside the work you were already doing.
Both work, and they suit different moments. Between deals you are staying in touch when nothing is moving, so the opening tends to come from a signal the client mentions. At a remortgage you are actively gathering the whole financial picture, so the data is already in your hands and the gaps are visible in the paperwork.
Then there is nothing to introduce, and you carry on with the remortgage. Make the check part of every remortgage, and make the introduction only where there is a gap to address.
No. Pointing out that a need exists, and offering to introduce the client to a firm that can advise on it, is not regulated advice. Recommending what the client should do about it would be. As long as you name the gap and offer the introduction, you are on the right side of the line. Telling the client to open or move a pension would cross it.
How to use a fixed-rate maturity date as a prompt to ask the client one wider question about pensions and savings, without giving regulated advice.
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How to use product transfers, rate holds and the years between deals to offer an introduction to E&G, without giving regulated advice.
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Life, critical illness and income protection sit within your own permissions and follow straight from the mortgage. What to advise on yourself, where that stops, and how the wider planning becomes an E&G introduction.
Read itYour firm keeps the mortgage and protection advice. Equity & General gives the pension, investment and estate planning advice, and a named partnership manager sets the arrangement up with you.