What clients need to understand before consolidating debts with a second charge
Lower monthly payments usually come with a longer term and a higher total cost, and unsecured debts become secured on the home.
The trade-off
Debt consolidation replaces several debts with one loan. A client who swaps unsecured debts for one secured loan may pay less each month, often because the term is longer, and more in total over that term.1,2
The security changes too. Debts that were unsecured become secured on the home, so falling behind could put the home at risk. MoneyHelper's test is simple: consolidating only makes sense if the total amount payable is less than before.1
Who the rules apply to
MCOB 4.7A.15R applies to the adviser. Where the main purpose of a mortgage is to consolidate existing debts, the adviser assessing suitability must take extra factors into account. The introducer's part is to set balanced expectations and pass on an accurate picture.2
What the adviser will consider
Under MCOB 4.7A.15R the adviser takes account, where relevant, of:2
- the costs of extending the period over which the debts are repaid;
- whether it is appropriate to secure debts that were previously unsecured;
- if the customer is known to have payment difficulties, whether an arrangement with their creditors would be more appropriate than a new mortgage.
What the FCA found
What to do before the referral
List every debt the client wants to clear, with its balance, monthly payment and whether it is secured. Note what the client wants to achieve, whether that is a lower payment, one bill or money for something else. The adviser needs that picture to make the assessment above.
When the recommendation comes back, look for the total amount repayable on the new loan beside the total still owed on the debts it replaces. That one comparison answers MoneyHelper's test.1
What to say to clients
Wording that keeps the conversation balanced:
- "It could lower what you pay each month, but you might pay more in total."
- "This loan would be secured on your home, unlike most of the debts it would replace."
- "The adviser will compare it with other options, including keeping things as they are."
- "I'll pass the adviser a full list of what you owe, so they see the whole picture."
Sources
- 1MoneyHelper, “What are debt consolidation loans?”Secured 'homeowner loans' put the home at risk if repayments are missed, and consolidating only makes sense if the total amount payable is less than before.
- 2FCA, “FCA Handbook: MCOB 4.7A Advised sales (MCOB 4.7A.15R, debt consolidation)”The extra suitability factors an adviser weighs when debt consolidation is the main purpose.
- 3FCA, “Second charge mortgage firms told to raise standards for consumers (12 March 2026)”The finding that advice steered customers towards debt consolidation.
- 4FCA, “Second charge mortgages – improving outcomes for consumers (good and poor practice, 12 March 2026)”Advisers not documenting why particular debts are or are not being consolidated.
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