Consumer Duty Hub

The Financial Conduct Authority (FCA) introduced Consumer Duty on Monday 31 July which sets higher and clearer standards of customer protection across the financial service industry.

The Duty applies to all regulated activities and is underpinned by a Consumer Principle which requires firms to act to deliver good outcomes for retail customers, three cross-cutting rules and four outcomes.

Consumer principle

At the heart of the Consumer Duty is the principle that a firm must take proactive measures to ensure that its retail customers are treated fairly and are provided with suitable financial products and services. A key element of this principle is the requirement for firms to act in a way that leads to the delivery of good outcomes for their customers.

Cross-cutting rules

The responsibility of firms to achieve the below four outcomes is reinforced by three overarching principles, firms must;

  • Act in good faith toward retail customers
  • Avoid foreseeable harm to retail customers
  • Enable and support retail customers to pursue their financial objectives

Four outcomes


Products and services

Firms should ensure that all products are fit for purpose and are designed to meet the needs, characteristics and objectives of customer.


Price and value

Firms should ensure that the price customers pay for a product or service provides value for money and is reasonable compared to the overall benefits.


Consumer understanding

Firms should ensure their communications mean customers can understand their products and services, their features and risks, and the implications of any decisions they make.


Consumer support

Firms should ensure they provide support that meets their customers' needs to enable them to realise the benefits of the products and services they buy, pursue their financial objectives and ensure they can act in their own interests.

Fair value assessment

We’ve conducted thorough assessments on all of our products to ensure they provide fair value to your customers.

To help you select the right product for your customers, we’ll be using an industry standard template that’s been created with UK Finance to ensure clear and consistent information is provided. The template will:

  • provide an understanding of the characteristics of our products;
  • help you understand the identified target market;
  • consider the needs, characteristics and objectives of any customers with characteristics of vulnerability;
  • identify the intended distribution strategy
  • ensure the product will be distributed in accordance with the target market.

Fair value assessments are available for:

Roles & Responsibilities

We’ve added a statement of our roles and responsibilities under Consumer Duty to our Broker Portal Agreement.

As per our normal process, you’ll need to confirm you accept them each time you log in.

View Broker Portal Agreement handsolutionarrowbtlresi

Further reading

For more information about consumer duty,
visit the FCA website.

Find out more handsolutionarrowbtlresi

Frequently Asked Questions

Your clients will always look to you for answers. So, it’s important you know where to turn to when you need some extra support with a challenging case. See if we have the solution you need.

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  • Coronavirus
  • Bank of England base rate change
  • Conveyancing
  • Consumer Duty Hub
  • Documents required on submission
  • Products and Cases
  • The applicant
  • The broker portal
  • The income or deposit

COVID-19 update – business as usual

As the impact of COVID-19 continues to affect us all, we wanted to thank you for your continued support. We remain dedicated to you and your customer and would like to reassure you that it’s business as usual here at Kent Reliance for Intermediaries. Our service remains strong, and we’re here to assist you and your customers as much as possible.

Full physical inspections for residential, buy to let applications will continue to take place through Connells via the usual process, in a COVID-secure manner. Connells have issued clear guidance surrounding property inspections. If this guidance isn’t adhered to, surveyors could choose not to proceed with a valuation, but still charge a fee for a visit.

Furlough payments, bounce back loans and CBILS

Residential applications

  • Furlough income is not acceptable as an income source.
  • SEISS payments aren’t acceptable as an income source.
  • Bounce back loans and CBILS aren’t acceptable as a source of deposit.

Buy to let applications

  • We’ll consider applications from landlords currently in receipt of furlough/SEISS payments, however top slicing is not available.
  • The latest bank statement is required to evidence rent / mortgage payments.
  • Bounce back loans and CBILS aren’t acceptable as a source of deposit.

There may be additional underwriting requirements. If you have any queries related to your application, please contact your business development manager.

  • Yes, for situations requiring face-to-face meetings, such as independent legal advice for Personal Guarantees or Signing of Occupiers Consents, in certain circumstances this may be undertaken by use of an electronic face-to-face medium. The solicitors acting should contact our underwriting team for further details.


  • As a regulated firm, our customer due diligence requirements are governed by Anti-Money Laundering legislation and therefore our scope to change is restricted. In order to meet legislation our requirement is that either Kent Reliance for Intermediaries or an authorised partner must see the original identification document prior to entering into the relationship.
  • In response to the COVID-19 situation, on a temporary basis and in order assist you and your customers, we’ll now accept the following documents uncertified.


  • A ‘clear’ photograph of the passport which must also be accompanied with a ‘selfie’ photograph of the holder.

Driving licence

  • A ‘clear’ photograph of the licence which must also be accompanied with a ‘selfie’ photograph of the holder. In addition your customer must use and provide a code where the driving licence can be validated.
  • If your firm has implemented a digital ID solution that captures and validates a customer’s identity document we may be able to accept this. We’re already accepting copies of the validation reports containing the picture ID from a number of Digital ID providers including Amiqus, TransUnion, Credas, Onfido, LexisNexis, TrustID and Yoti.
  • Alternatively, your customer can send their identity document directly to us. It’s recommended that all documents are sent via registered post.

Bank of England base rate change

This is the official interest rate set by the Bank of England’s Monetary Policy Committee.

It has increased the base rate from 5.00% to 5.25%.

If you have a mortgage product that is linked to the Bank of England Base rate, then your monthly payments will change. We will confirm the changes in writing to you shortly.

No, your mortgage Terms and Conditions remain the same.


Limited Company/LLP

For any limited company/LLP application, a member of our limited company solicitor’s panel must be instructed by yourself or the applicant.

You will be provided with their estimated fees (in accordance with our fee scale – either dual representation or sole representation). 

Please note that the earlier this is carried out, the timelier and more efficient your conveyancing process is likely to be. This is because your selected solicitor will be able to commence the initial checks prior to your offer being issued.

View Panel

Shared ownership

For any shared ownership application, a member of our shared ownership solicitors panel must be instructed by yourself or the applicant.

Please note that the earlier this is carried out, the timelier and more efficient your conveyancing process is likely to be. This is because your selected solicitor will be able to commence the initial checks prior to your offer being issued.

View Panel

Consumer Duty Hub

No, the key difference between Consumer Duty and TCF is that Consumer Duty sets the expectation to provide fair outcomes for customers and the new expectation for firms to support providing good outcomes.

It’s a more proactive approach than TCF, which was reactive in its approach to providing good outcomes.

We’ll be communicating this in due course. We want to exchange data in a common industry format and for this we’re waiting on a template being defined by UK Finance. This will help facilitate consistent sharing of MI across the industry.

We’ll always treat any customer who’s been identified as vulnerable individually, fairly and appropriately. We’ll communicate with them in a manner suitable to their circumstances and using any communication needs they may have, ultimately ensuring they’re generally supported in an appropriate manner. We’ve identified as part of our target market that a proportion of our customers may have vulnerable characteristics. Therefore, if we identify the vulnerability, or if you disclose a client’s vulnerability to us, we’ll record this and provide appropriate support. This may include contacting the customer, you or both to check if additional information is required to aid understanding or find out if we need to change how and when we communicate.

No, we don’t anticipate any changes to our application processing service levels because of Consumer Duty.

You must read and accept our terms and conditions each time you register and submit business on our portal. We haven’t changed our terms and conditions but have added some information around roles and responsibilities in there in light of Consumer Duty. As it may have been a while since you had reviewed and accepted these terms and conditions, we wanted to give you an opportunity to review the additional information before you accept the terms and conditions again. In order to submit business we always ask you accept our terms and conditions. If you do not accept the terms and conditions you will be unable to submit any new applications.

As per our normal processes, you’ll need to confirm you accept them each time you log in.

Products and Cases

Yes, fees can be added to the loan. This will not affect the LTV band of the mortgage product.

There is no upper limit to the number of properties in a portfolio.

This is determined by the individual applicant and the product parameters.

We consider a range of codes but typically 68209 is a common one.

The applicant

Yes, they must have had their contract renewed at least once, with at least 6 months remaining on the current contract.

Experian is used for credit reference purposes.

Guarantors are considered subject to status, credit checks and assessed on ability to afford the repayments taking into consideration all existing commitments. The guarantor must have obtained independent legal and financial advice.

Please refer to the product specific pages for guidance on what may be considered.

The broker portal

The updated system is designed to provide a streamlined and simplified process, enabling us to process your cases quicker and more efficiently.

Along with improved AIP decision making, we offer one single journey for submissions and case tracking, making it easier to navigate. Plus, we also send regular case updates out via email and text message.

If you’re already registered with us, the good news is that you don’t need to change anything. The only difference is that you’ll be asked to provide some new security details the next time you log in to the updated portal.

If you're new to doing business with us, you must register online before using the new system. You can do this here.

When you log in from our website, you’ll have a choice of logins, one of which will be for the previous Broker Portal. This is what you’ll have to use to progress an existing application.

Please note that you can upload documents or add notes to existing applications but you cannot start a new application or AIP. All new illustrations, AIPs and full applications will have to be submitted on the new portal.

You’ll be able to access product transfers by logging into the previous Broker Portal via one of the login options on our website.

You’re only able to use the solicitors on our approved panels. If the solicitor your client wishes to use isn’t on our approved panel, the solicitor firm needs to register to be on our panel before you can select that solicitor firm on the application. More information on how solicitors can register on our panel can be found here.

If you’re submitting a limited company or shared ownership application, you’ll only have access to the solicitors that are on our closed panels.

The new portal is compatible with Chrome, Firefox, Safari and Edge.

This is so that we can underwrite your applications at the point of submission therefore providing a faster service for you and your clients.

Yes – we’ve increased the maximum size of the document from 5MB to 10MB. Please ensure you upload the document against the correct checklist item.

If you have any questions about the new portal or your current cases, contact our broker liaison team on 01634 835791 and they’ll be happy to help.

The income or deposit

Income for the affordability assessment will be based on the directors salary and dividends from the accounts. Retained profits should be viewed as an indicator of the health of a business rather than a means for a borrower to afford a mortgage and care should be taken to consider whether a business would remain viable if any retained profits were withdrawn for personal usage.

Rather than the earned income, it is the ability of the security property to generate income that is used to assess the affordability of the application. However, establishing employment and earned income provides comfort that the applicant is more likely to be in a position to cover any sporadic void periods. Underwriters may request evidence of personal income status on an individual case basis.

Yes, a gifted family deposit is accepted with no additional deposit required from the borrower, subject to gift coming from an immediate family member, the amount is a non-refundable gift, the donor will have no interest in the property and a deed of gift indemnity policy is in place on completion.

Yes, unless the profit has been steadily increasing where income will be taken from the net profit for the latest year.

Benefit income is not acceptable for lending purposes.

For builder/vendor incentives, the value of the deposit/incentive is deducted from the lower of the purchase price/valuation and the loan is based on the lower amount. The borrower must provide the required level of deposit to meet product parameters (e.g. if max LTV is 85%, the borrower must provide at least 15% from their own resources).

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