ASEW · Assessment of Mortgage Advice Knowledge
These cases start with an existing mortgage and ask what to do next: switch product, remortgage, borrow more, add a second charge, consolidate debts, or change who is on the loan. The marks come from knowing which changes need a full affordability assessment and which do not, the disclosure each change triggers, the cost of early repayment charges, and the extra suitability rules for debt consolidation. Rules changed on 22 July 2025 (FCA PS25/11), so expect questions that reward the current position and punish the old one.
9 min read6 sections
Checked against: Walbrook (formerly LIBF) CeMAP specification v14 (July 2026), Appendix 5, ASEW/ASSC LO1, LO2 (AC2.6), LO3, LO4 (AC4.3); FCA Handbook MCOB 4.4A.8AR, 4.7A.15R, 4.8A.7R, 4.8A.10R, 7.6, 11.6.3R, 11.6.4E, 11.6.16R, 11.9, 12.3.1R; FCA PS25/11; HMRC SDLT transfer guidance; checked 11 Oct 2026. Independent prep, not endorsed by Walbrook (formerly LIBF).
Start by labelling the change. Every question then follows from three tests: does it need a full affordability assessment, what must the customer receive before applying, and what does it cost to leave the current deal. The ASEW unit tests these under LO3 and LO4 (Walbrook CeMAP spec v14, Appendix 5).
| Change | Full affordability? | Disclosure before applying | ERC? |
|---|---|---|---|
| Product transfer, same lender, no extra money | No (MCOB 11.6.3R) | Whole-loan ESIS (MCOB 7.6.18R) | Only if switching during a fix |
| Remortgage to a new lender, no extra money | Yes, or MCOB 11.9 modified test | ESIS (MCOB 5A) | Yes if inside the fix |
| Further advance | Yes (extra borrowing) | ESIS on the advance plus total borrowing (MCOB 7.6.7R, 7.6.9R) | No; existing product stays |
| Second charge | Yes, first mortgage payment as commitment | ESIS (MCOB 5A) | No; first charge untouched |
| Add or remove a borrower |
Every note. Every question. One pass.
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From ≈£2.72/mo on the Until-you-qualify pass (18 months)
| Yes (MCOB 11.6.4E) |
| Whole-loan ESIS to remaining or new parties (MCOB 7.6.22R) |
| Usually no, if same lender |
| Term reduction (from 22 Jul 2025) | No full test; consider under Consumer Duty | Information on the new payment | Lender terms |
Trap: treating every change with the same lender as exempt from assessment. Extra borrowing and a change of borrower both need the full test.
Takeaway: Label the change first. Then ask: full assessment or not, which disclosure, and what it costs to leave the current deal.
A product transfer with the same lender needs no full assessment if there is no extra borrowing and no material change (MCOB 11.6.3R). It can be execution-only if the lender presents every product the customer is eligible for (MCOB 4.8A.10R). Since 22 July 2025 the old ‘interactive dialogue’ advice trigger is gone.
A new lender must normally assess in full, but may elect the MCOB 11.9 modified assessment where there is no extra borrowing (fees aside), the same property, and no payment shortfall now or in the last 12 months. Since 22 July 2025 the new deal must be more affordable than the existing contract or the deal the current lender has indicated (MCOB 11.9.5R).
| Two-year cost comparison (£182,000, 17 years) | Working | Total |
|---|---|---|
| Product transfer at 4.29%, no fee | £1,258.20 × 24 | £30,196.80 |
| New lender at 3.99%, £999 fee upfront | £1,230.11 × 24 + £999 | £30,521.64 |
| Doing nothing: SVR 7.49% vs 1.89% fix | £1,579.98 − £1,043.84 | +£536.14 a month |
Trap: comparing headline rates without adding fees over the deal period, or thinking MCOB 11.9 is only for customers of closed-book lenders.
Takeaway: Same lender, no extra money: no full check. New lender: full check or MCOB 11.9. Compare total cost over the deal, fees included.
