AR detail
SUP 12.6A annual fitness review · 2025 cycle

Pemberton Mortgages

Aggregated across the year for board sign-off. Feeds the firm-level self-assessment under PS22/11 and the annual Consumer Duty board report.

01

Overview

01 / 07
Current risk score
71 / 100
High
File-review average
66 / 100
across 6 reviews
Breaches this cycle
2
0 notified to FCA
New business
£32.7m
Complaints
27
Permissions
2
02

Risk trajectory

02 / 07
Monthly composite score · last 12 months
71
71
03

Breach summary

03 / 07
  • Minordata protectionin remediation26 Mar
    Lost USB drive containing 14 customer applications
  • Moderatedata protectionclosed12 Sept
    Customer file emailed to wrong recipient
04

File review summary

04 / 07
Reviews completed
6
Average score
66 / 100
Failing scores (<65)
3
Last 12 reviews
05

MI return trend

05 / 07
2025 Q2
£7.1m
0 complaints · 2 breaches
2025 Q3
£4.5m
1 complaint · 0 breaches
2025 Q4
£3.6m
3 complaints · 1 breach
2026 Q4
£6.5m
7 complaints · 0 breaches
06

Consumer Duty outcomes

06 / 07
Products and services
On track

Target market alignment confirmed for all distributed products.

Price and value
On track

Fee structure within firm-wide fair-value benchmark.

Consumer understanding
Watch

Two reviews flagged disclosure-quality concerns. Action plan agreed.

Consumer support
On track

27 complaints over the cycle. 180% upheld; root causes addressed.

07

Director sign-off

07 / 07

By signing off this annual fitness review packet you confirm that, in accordance with SUP 12.6A.5R, you have considered the AR's activity, business, fitness and propriety, and the Consumer Duty outcomes set out above. The sign-off is recorded in the audit chain with director attribution and timestamp.