Consumer Duty

Our Commitment to Consumer Duty

The Equity Release Network (“TERN”) is committed to delivering good outcomes for consumers in line with the Financial Conduct Authority’s Consumer Duty (Principle 12).

Although TERN does not provide regulated financial advice to consumers directly, we play an important role as a network, introducer and oversight body supporting authorised advisers who do. We recognise that Consumer Duty applies across the entire consumer journey, including pre-advice interactions, adviser onboarding, oversight, and ongoing monitoring.

This page explains how TERN supports Consumer Duty and how it interacts with our Complaints Procedure where concerns arise.

TERN’s Role Under Consumer Duty

TERN operates as a directly authorised network supporting appointed representative firms and individual advisers specialising in later-life lending.

Our responsibilities under Consumer Duty include:

• setting clear standards for advisers operating within the network
• ensuring advisers are appropriately trained, competent and supported
• overseeing advice quality and consumer outcomes
• operating fair, transparent and compliant introducer processes
• monitoring data, MI and trends to identify potential harm early

While responsibility for individual advice and product recommendations rests with the adviser or firm providing that advice, TERN retains oversight responsibility to ensure that the network operates in a way that supports good consumer outcomes.

The Four Consumer Duty Outcomes

TERN aligns its oversight framework with the FCA’s four Consumer Duty outcomes:

1. Products and Services

TERN only permits advisers to recommend regulated later-life lending products that are appropriate to the consumer’s needs and circumstances and offered by authorised lenders. We support advisers in understanding product features, risks and suitability considerations specific to later-life lending.

2. Price and Value

TERN expects advisers to assess whether products represent fair value for consumers, taking into account costs, benefits, risks and long-term implications. At network level, we monitor adviser practices and outcomes to identify any potential value concerns.

3. Consumer Understanding

We support clear, fair and not misleading communications. Our systems, processes and guidance are designed to help advisers explain complex later-life lending products in a way consumers can understand, particularly where vulnerability may be present.

4. Consumer Support

TERN expects advisers to provide appropriate levels of support throughout the advice process and beyond. At network level, we monitor adviser behaviour, response times, complaint handling and post-advice support to ensure consumers are treated fairly.

Vulnerable Customers

Later-life lending often involves consumers who may be vulnerable due to age, health, life events or financial circumstances.

TERN places particular emphasis on:

• identifying potential vulnerability
• ensuring advisers are trained to recognise and respond appropriately
• supporting advisers with guidance, tools and escalation routes
• monitoring outcomes for vulnerable consumers

Protecting vulnerable customers is a core element of our Consumer Duty framework.

Introducer Activity and Find an Adviser

Where consumers submit enquiries via TERN’s Find an Adviser service, TERN acts as an introducer only.

Our introducer processes are designed to:

• treat consumers fairly at the pre-advice stage
• ensure enquiries are passed to appropriately authorised advisers
• avoid bias, pressure or misleading information
• support a smooth transition into regulated advice

TERN does not provide product recommendations or regulated advice via its website.

Complaints and Consumer Duty

Complaints are an important source of insight into consumer outcomes and potential harm.

TERN’s Complaints Procedure explains how complaints are handled depending on their nature, including:

• complaints about TERN’s introducer services or oversight
• complaints about advice provided by an adviser or firm
• complaints involving individual advisers operating as sole traders

Where a complaint relates to regulated advice, it will be handled by the adviser or firm responsible for that advice. Where appropriate, TERN will oversee the handling of the complaint to ensure it is managed fairly, promptly and in line with FCA requirements.

TERN uses complaint data as part of its Consumer Duty monitoring to identify trends, risks and opportunities to improve outcomes across the network.

Please refer to our Complaints Procedure for full details on how to raise a complaint and how complaints are handled.

Monitoring, Oversight and Continuous Improvement

TERN actively monitors consumer outcomes across the network through:

• management information and data analysis
• file reviews and quality assurance
• complaint monitoring and root-cause analysis
• adviser supervision and training
• feedback from consumers and advisers

Where issues are identified, TERN takes appropriate action, which may include additional training, increased supervision, changes to processes or, where necessary, enforcement action.

Our Commitment

TERN is committed to embedding Consumer Duty into everything we do, not as a one-off regulatory requirement, but as an ongoing standard of behaviour.

We believe that good consumer outcomes, strong adviser support and robust oversight go hand in hand. Our approach is designed to protect consumers, support advisers and raise standards across the later-life lending market.

Further Information

If you would like more information about how TERN applies Consumer Duty, or if you have concerns about consumer outcomes, please contact us or refer to our Complaints Procedure.