Blog: Trusted data, not just more data: why the FCA's mortgage sprint findings matter

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When the FCA recently published the outcomes of its Mortgages and Open Finance Policy Sprint, one message stood out above everything else: access to more data is no longer the problem. The problem is making that data trusted.

To me, this represents an important shift in the conversation around open finance and mortgages. For years, the industry has focused on connectivity – how we get more data from more sources into the mortgage journey. The FCA’s findings suggest we’re now asking the harder question: what can we do to make sure that those receiving the data can rely on it and act on it?

Having participated in multiple FCA mortgage sprints and contributing to the work LMS is doing in the wider mortgage and property ecosystem, I think the industry has moved past asking whether open finance – and other emerging smart data schemes – can improve mortgage journeys, to what it will take to make that happen.

A welcome reframing

Today, information about someone’s identity, source of funds, rental payments or property can sit across a whole range of different organisations and systems. Bringing that information together earlier has obvious potential to make the process more efficient and reduce the amount of information consumers have to provide repeatedly.

Trusted, reusable evidence reduces that burden on home movers. It could also help people whose circumstances don’t fit neatly into standard assessments, such as those with fluctuating incomes or a strong record of paying rent, who are too easily overlooked today. The test of success is whether it becomes easier for home movers to get a mortgage, not just how much data is moving.

Getting there takes more than connecting data sources; that work is still in progress, and there is plenty left to do to realise interoperability at scale. But the more challenging part is providing the confidence in the data when it arrives.

A lender may be able to access a piece of information, but does it trust it enough to use it in a lending decision? A mortgage adviser might be able to see it, but can they confidently rely on it? And what about a conveyancer, who will be responsible for assessing information as part of the legal work underpinning a transaction?

Adding trust to data

The FCA’s report describes the need for data to be ‘decision-grade’, accurate, current, standardised and capable of being recognised as evidence. This draws a clear distinction between data that can be accessed and data that is trusted enough to be acted on.

Today, this is managed through commercial relationships. A lender trusts a data provider because it has worked with them over time, carried out due diligence and built confidence in their processes and controls. Trust is earned and is specific for a given use case.

But that model only works between parties who already have a relationship. A conveyancer, a broker or a surveyor working in the same transaction will often have no existing relationship with that provider. If we want data that is reusable across a transaction, then the trust that underpins it needs to travel with it.

An accreditation model can help establish that a supplier is legitimate. But legitimacy isn’t the same as trust in the data itself. For a professional to rely on information they didn’t source themselves, they need to know more than just who supplied it. They also need to know it hasn’t been altered since it was issued, what supports its accuracy, and what they are permitted to do with it.

That is what the industry needs to agree on. But agreeing on it requires starting with the professionals who will have to stake their judgement on it.

Put the people making the decisions at the centre

The FCA’s sprint participants identified four questions that sit at the heart of this: who is responsible if the original data is wrong; if it is transformed incorrectly as it moves between systems; if several providers each contribute to a decision that is later found to be incorrect; and what happens when something goes wrong and a consumer needs redress.

Conveyancers are a particularly important part of this conversation. They are responsible for the legal work that underpins a property transaction and they carry accountability for the outcome.

If the industry wants these professionals to trust shared data, it needs to understand what would satisfy those concerns. We cannot design a system and then ask conveyancers to fit within it. We need to co-create it with them.

I believe some of the scepticism to digital property initiatives has come from a perception that decisions are being made around the profession rather than with it. Building trust in the system and in the data comes from ensuring that those relying on it have a voice in the standards it is expected to meet. We have already spoken to a range of stakeholders and that conversation is still open. Getting varied perspectives now is what will make this work for everyone in the longer term.

Where NPTN fits

The FCA’s own conclusion is that the sprint outcomes “reinforce the importance of the focus on foundational enabling infrastructure”. Participants were clear that trust needs to be built into the data-sharing architecture rather than left to awareness campaigns, and that the infrastructure to verify where data came from, how reliable it is and whether it can be treated as evidence is not yet in place.

The FCA has said its next phase of work will look at the data-sharing architecture, roles and responsibilities, and components such as identity and verification, authorisation and certification.

This is where infrastructure such as the National Property Transaction Network (NPTN) has a role to play.

Sprint participants described the goal as “capture once, verify once, reuse safely across the ecosystem.” That is the right ambition. But reuse only works if the data carries the evidence needed to rely on it. Connectivity alone doesn’t solve that.

NPTN is designed to enable that trust layer, so that data moving through the network can carry the attributes that allow any party in the transaction to assess whether they can trust it: proof that it hasn’t been altered since it was issued; provenance, establishing where it originated and who stands behind it; evidence, the supporting information that justifies confidence in it; and context, defining how it can be used and by whom.

Together, these attributes mean that data collected at one point in a transaction can be trusted and reused at another, even by a party with no prior relationship with the original supplier. The lender, the conveyancer, the broker and any other stakeholder can work from the same trusted data rather than each independently sourcing and checking the same underlying facts.

NPTN draws on LMS’s existing relationships across the conveyancing ecosystem and connects lenders, law firms, estate agents, brokers and other participants. But it is not intended to replace professional judgement or independent legal advice. The infrastructure enables trust. The professionals still apply their expertise to it.

The next conversation

The question now is whether the industry can come together to treat the solution as a common foundation or leave it to individual providers to solve in isolation.

The attributes that allow data to be trusted (proof, provenance, evidence and context) should come, in my opinion, from an open common standard, rather than being proprietary to any one provider. They need to be an agreed baseline that all participants in a property transaction can rely on.

The FCA describes this sprint as marking a shift from demonstrating the potential of open finance to actively advancing the foundations required to realise it. I cannot help but think that the success of open finance will come from creating a shared layer of trust as part of that foundation, built with the professionals who will have to rely on it.

Richard Saville, head of architecture, LMS


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