Equity Release & Later-Life Finance
How to make a complaint about an equity release product or adviser
A step-by-step guide to complaining about an equity release product or adviser in the UK: internal complaints, the Financial Ombudsman Service, timescales, and what to expect at each stage.
By David (Editorial) - Former independent financial adviser
Published · 8 min read
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How to make a complaint about an equity release product or adviser
This guide is for anyone who has taken out a lifetime mortgage or home reversion plan and believes something went wrong: perhaps you were mis-sold the product, given unsuitable advice, or have encountered a problem with how your lender has administered your loan. By the end, you'll know exactly how to raise a formal complaint, what timescales apply, and what to do if the response you receive doesn't satisfy you.
The process is more straightforward than most people expect. You don't need a solicitor, a claims management company, or anyone charging you a percentage of a payout.
Step 1: Identify who your complaint is against
Your grievance might sit with one party or two. The lender (Aviva, Legal & General, Pure Retirement, More2Life, and so on) is responsible for how the product has been administered. The adviser, or the firm they worked for, is responsible for the suitability of the advice you received.
These are separate complaints and, in many cases, separate regulated entities. Mis-selling, unsuitable advice, or a failure to explain compound interest properly sits with the adviser. Errors in statements, charges applied incorrectly, or a refusal to allow a property move all sit with the lender.
You can complain to both at the same time, but keep the correspondence separate. It makes things cleaner if the case escalates.
Step 2: Gather your documents
Before you write a single word of complaint, assemble what you have. The more specific your evidence, the harder it is for a firm to deflect you with vague reassurances.
You're looking for:
- The key facts illustration (KFI) or European standardised information sheet (ESIS) you were given before you signed
- The suitability letter from your adviser, explaining why this product was recommended for you specifically
- The offer document from the lender
- Any meeting notes or records of conversations (even if handwritten at the time)
- Correspondence since the loan completed
If you don't have all of these, that's fine. Request copies from the firm. They're legally obliged to keep records for a minimum of six years, and in equity release cases often longer, given the nature of the product.
Step 3: Submit your complaint in writing to the firm
Phone calls are not formal complaints. A firm's call handler may be helpful, but a verbal exchange starts no clock and creates no paper trail. Write to them.
Your letter or email doesn't need to be formal legal language. It needs to be clear. Include:
- Your full name, address, and account or policy number
- A description of what happened, in the order it happened
- Why you believe this was wrong (unsuitable advice, a charge you weren't told about, an inaccuracy in documentation)
- What you want: an apology, a correction to your account, financial compensation, or a combination
Address it specifically to the complaints department. For lenders, this is usually listed on their website under "how to complain" or in your original policy documentation. For advisory firms, address it to the compliance officer if you can find the name.
Send it by email if you can, so you have a timestamp. If you post it, send it recorded delivery and note the date.
Step 4: Wait for the firm's final response
Under FCA rules, the firm must acknowledge your complaint promptly, usually within five business days, and issue a final response within eight weeks.
In practice, most straightforward complaints receive a substantive response well before eight weeks. More complex cases involving suitability, where the firm may need to pull adviser files and call recordings, often take longer to investigate internally, though they must still respond within the deadline.
The final response letter will either uphold your complaint (fully or partially), offer a settlement, or reject it. Read it carefully. If they uphold it, check that the remedy they're offering actually addresses your loss. A goodwill payment of £200 is not the right outcome if your complaint concerns advice that cost you tens of thousands of pounds in avoidable compound interest.
If you haven't heard anything after eight weeks, that absence of a response is itself grounds to escalate.
Step 5: Refer to the Financial Ombudsman Service if needed
You can take your case to the Financial Ombudsman Service (FOS) if:
- The firm has issued a final response you're not satisfied with, or
- Eight weeks have passed since you submitted your complaint and you haven't received a final response
You have six months from the date of the firm's final response letter to refer the case to FOS. Don't let that deadline slip past.
The FOS is a free, independent service. You can submit your case online at financial-ombudsman.org.uk, by post, or by phone (0800 023 4567). You'll need to upload or post copies of your correspondence with the firm and a summary of your complaint.
The service covers complaints about firms regulated by the FCA, which includes all lenders and advisers operating in the equity release market. If your adviser was a member of the Equity Release Council (as all reputable firms should be), that membership sits alongside FCA authorisation rather than replacing it.
Step 6: Engage with the Ombudsman's process
The FOS will write to the firm on your behalf, asking for their file and their response to your case. This can take a few months. The Ombudsman's current published average for resolving a complaint is around six months for simpler cases, and longer for contested or complex ones. In my experience, equity release complaints involving suitability arguments tend to sit at the more complex end.
You'll be assigned a case handler who may contact you with questions or to clarify elements of your submission. Reply promptly and keep copies of every document you send.
The Ombudsman will produce a provisional decision, giving both parties a chance to respond before a final decision is issued. The final decision is binding on the firm if you accept it. You're not obliged to accept it: if you reject the Ombudsman's final decision, you retain the right to pursue the matter through the courts, though this rarely makes practical sense for most complainants.
If the Ombudsman finds in your favour, the firm can be directed to pay compensation of up to £430,000 (as of the current limit). Cases involving larger losses can still be heard by the FOS, but the award is capped at that figure; anything beyond it would require court action.
What good complaints look like
The strongest equity release complaints I've seen upheld tend to share a few characteristics. They're specific about what was said and what wasn't. They reference the product illustration and compare it to what the adviser explained at the time. They show that the customer's circumstances (other assets, income needs, desire to leave an inheritance) were either misunderstood or ignored.
Vague complaints about feeling "mis-sold" without supporting detail are harder to pursue. If you can point to a specific paragraph in your suitability letter that contradicts your actual circumstances, that's far more useful than a general sense that the product wasn't right for you.
Frequently asked questions
Will complaining affect my existing equity release plan?
No. Making a complaint does not change the terms of your lifetime mortgage or give the lender any right to alter your arrangement. Your right to remain in your home is protected.
Can I complain if my adviser has retired or the firm has closed?
Possibly. If the firm is FCA-regulated and has since closed, the Financial Services Compensation Scheme (FSCS) may be able to help if the firm is declared "in default". The FOS can advise on this if you contact them before submitting a formal complaint.
Does the Equity Release Council handle complaints?
The Equity Release Council sets product standards and a code of conduct, but it is not a dispute resolution body. Formal complaints go through the firm's own process and then the FOS. The Council can sometimes assist with general queries about what members' obligations are.
I used a mortgage broker, not a specialist equity release adviser. Does the same process apply?
Yes. Any FCA-authorised adviser who provided advice on a regulated mortgage contract, including lifetime mortgages, is subject to the same complaints framework.
What if I want to complain about something that happened before I completed the plan?
Complaints about the advice and sale process are some of the most common, and the Ombudsman handles them regularly. The key question is whether you can show that the advice given was unsuitable for your circumstances at the time.
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About the author
David (Editorial)
Former independent financial adviser
David writes the site's finance guides. His editorial voice reflects a career advising retirees on income drawdown, equity release, and later-life planning.
Focus areas: Equity release, pension drawdown, annuities, inheritance planning.
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