Brokers warn that meeting compliance standards does not always mean clients fully understand mortgage advice
Mortgage advice is built on suitability, disclosure and process, but that does not necessarily mean it is easy to understand.
For some brokers, that gap is becoming harder to ignore. NHS guidance cites that around one in seven people in the UK are neurodivergent, raising questions about how well a process built around long documents and standardised communication works in practice.
Nouran Moustafa, executive financial and mortgage adviser at Roxton Wealth, believes the industry remains too focused on proving information has been delivered, rather than ensuring it has been absorbed.
“There is a big difference between speaking about a problem and just talking about it for the sake of likes and reach, which we can all do, and there is a totally different league, which is acting upon the problem.”
For Moustafa, the issue is not regulation itself, but how it is applied. Compliance, she argues, is too often treated as a constraint on communication, rather than a framework for making advice genuinely understandable.
“As long as you are a regulated individual, you have to follow this set of standards,” she said. “So instead of thinking that we are going to change the standards, change the words and waste everyone’s time and energy, we can just add some things that complement those standards.”
In practice, that means adapting delivery rather than rewriting the rules; splitting long fact-finds into shorter sessions, supplementing formal documents with voice notes, or highlighting key points in more accessible formats.
“If I get a client with ADHD, I am not going to say, ‘Okay, let’s change the whole process for you,’” she said. “I will follow the same standards; I’ll just follow the standards in a different way.”
That distinction cuts to a broader weakness in the mortgage process. In practice, it often assumes that once a document has been sent, understanding has been achieved, whether or not that is actually the case.
“Even sometimes, as an advisor, I get so tired from reading the suitability report that I think, ‘Oh my God, why do I have to read that?’” Moustafa said. “So imagine: if I’m the advisor thinking that, what do you think the client is saying?”
The issue is not limited to neurodiverse clients. It reflects a wider gap between how advice is delivered and how it is actually received, particularly where clients are less likely to challenge what they do not understand.
“Most clients who don’t have neurodiverse needs tend to speak up for themselves,” she said. “Those with neurodiverse needs are less likely to, the first thing that comes to their head is, ‘I might be the problem.’”
That raises a more uncomfortable question for the market. If a client leaves the process confused, overloaded or reluctant to ask questions, has the industry met the spirit of “fair, clear and not misleading” communication, or simply fulfilled a compliance requirement?
Moustafa argues that compliance, properly understood, is aligned with clearer communication rather than in conflict with it. “We need to recognise that people process things in different ways. Not everyone wants to read a 20-page document.”
In her view, clearer communication should not be treated as a niche adjustment, but as a baseline standard.
The implication for brokers is harder to ignore. Neurodiverse clients expose the limits of a process built around documents and standardised delivery, but the underlying issue is broader. If advice is genuinely meant to be suitable, the industry may need to confront whether being compliant is the same thing as being understood.
