PRA High LTI Lending: The Firm-Level 15% Cap Ends on 28 October

RegReportingDesk card: PRA, Prudential Regulation Authority, United Kingdom

On 14 October 2026 the Prudential Regulation Authority and the Financial Conduct Authority published their final policy on high LTI lending: PRA policy statement PS19/26 (FCA PS26/20), a new PRA supervisory statement, SS2/26, and replacement FCA general guidance, FG26/11. From 28 October 2026 the Housing Part of the PRA Rulebook stops capping each lender’s high loan to income mortgages, those at 4.5 times income or more, at 15% of the regulated mortgage contracts it enters into. The Financial Policy Committee’s 15% limit survives as a market aggregate, and the regulators can ask lenders above 15% to cut back if that aggregate becomes inconsistent with it.

The change swaps a limit each firm could police alone for one that depends on the whole market. From 28 October 2026, lenders may exceed a firm-level high LTI flow of 15%, subject to the applicable prudential requirements and supervisory expectations. Until that date, the existing firm-level restriction continues to apply unless the lender has applicable interim relief. SS2/26 expects risk appetite limits under board oversight, management information on current and expected high LTI flow, and assurance that the firm can reduce future flow in accordance with any adjustment timetable subsequently published by the PRA. The numbers behind that machinery come from the FCA Product Sales Data that mortgage lenders already submit, so the quality of a firm’s PSD001 submissions now shapes both the market figure and its own adjustment baseline.

The first published aggregate puts the single-quarter figure at 14.1% for 2026 Q2, up from 9.7% in 2025 Q3. The PRA’s high LTI webpage states that the regulators have not set any current expectations on firms to reduce their high LTI flow.

Related reading: PRA Pillar 2A Review Phase 1: The 1 January 2027 Reset

Key dates in the high LTI lending changeover

Fourteen days separate the policy statement from commencement. The sequence runs from the FPC’s recommendation in 2025 to the next scheduled quarterly publication of the aggregate, due in 2026 Q4.

Date What happens
9 July 2025 FPC Record published with the recommendation that the PRA and FCA amend implementation of the LTI flow limit
July 2025 Interim relief opens: a PRA modification by consent disapplying the firm-level 15% limit, and FCA individual guidance; FCA guidance revised as FG25/4 on 11 July 2025
1 April 2026 Joint consultation published: PRA CP6/26 and FCA CP26/12
1 July 2026 Consultation closes
14 October 2026 PS19/26 (FCA PS26/20), SS2/26 and FG26/11 published; PRA publishes the first aggregate high LTI figures
28 October 2026 Instrument, SS2/26 and FG26/11 take effect; interim modifications and FCA individual guidance fall away
2026 Q4 PRA publishes the 2026 Q3 aggregate with supporting volume data

CP6/26 had extended the interim arrangements to 31 December 2026 or the earlier commencement of the new rules. PS19/26 paragraph 2.14 confirms that the relevant directions fall away automatically on 28 October 2026 and that firms which consented to the PRA modification, or applied for FCA individual guidance, need take no action.

What PRA2026/27 deletes from the Housing Part

The rule change itself is short. The PRA Rulebook: CRR Firms: Non-CRR Firms: Housing (Amendment) Instrument 2026, numbered PRA2026/27, was published on 14 October 2026 and comes into force on 28 October 2026. Its annex rewrites rule 2.1 and removes the machinery built around the old limit.

Provision Before 28 October 2026 From 28 October 2026
Rule 2.1 High LTI contracts entered into in the relevant period may not exceed 15% of all regulated mortgage contracts in that period A firm must conduct its business of entering into high LTI mortgage contracts in a prudent manner
Rules 2.2 to 2.6 A group firm could allocate its high LTI allowance to other group members, with a record of allocations Deleted
Rule 1.11, regulated mortgage contract Disregards re-mortgages with no change to the principal sum outstanding, lifetime mortgages and contracts that are not first charge Also disregards retirement interest-only mortgages and further advances

The instrument adds a definition of further advance (further credit to an existing borrower, secured on the same property, whether under a new contract or by varying an existing one), takes the meaning of retirement interest-only mortgages from the FCA Handbook, and switches the lifetime mortgage definition from the PRA Handbook to the FCA Handbook. The chapter heading moves from High Loan to Income Allowance to High Loan to Income Lending. “Allowance” was a counting concept: a number of contracts a firm could enter into, part of which it could hand to another group member. The replacement rule is qualitative, and the quantitative content now lives in SS2/26 and FG26/11 as expectations.

Group allocation goes with rules 2.2 to 2.6. In its place, where more than one firm in a group is above the de minimis threshold, references to a firm are read as the group, and only the above-threshold firms count towards the group’s flow (SS2/26 paragraph 3.1 and footnote 9; FG26/11 paragraph 16).

Removing the firm-level cap leaves the number 15% doing three jobs. It is the FPC’s aggregate limit, which the regulators monitor. It is the line from which a firm’s excess is measured when an adjustment is announced. And while adjustment expectations are in force, it is the level that firms currently at or below 15% are expected not to cross (SS2/26 paragraph 3.5; FG26/11 paragraph 22). An internal policy note that records only “15% cap removed” loses the second and third of those, and those are supervisory expectations relevant to a lender during a market-wide adjustment, rather than a reinstated individual cap under Housing rule 2.1.

Who the PRA high LTI lending rules reach, and what stays on below de minimis

The split between the two regulators follows authorisation. PRA-authorised mortgage lenders, and subsidiaries of PRA-authorised firms that lend, sit under the Housing Part and SS2/26; PS19/26 paragraph 2.2 lists banks, building societies, friendly societies, industrial and provident societies, credit unions, PRA-designated investment firms and overseas banks for their UK branch activities, with the rules applied at UK subsidiary level to firms not already in scope. FG26/11 applies to FCA-authorised mortgage lenders that are not PRA-authorised or subsidiaries of PRA-authorised firms. PS19/26 paragraphs 2.2 and 2.3 describe how the scope of the FCA guidance interacts with the PRA framework.

The de minimis threshold keeps its substance. A firm is below it if, during both of two consecutive sets of four quarters, it entered into regulated mortgage contracts with total credit under £150 million, or fewer than 300 regulated mortgage contracts in each set (SS2/26 paragraph 1.3; FG26/11 paragraph 10). A firm that crosses it comes within the relevant paragraphs from the start of the second quarter after the final quarter used in the determination, and drops out again if it falls back below (SS2/26 paragraph 1.4; FG26/11 paragraphs 14 and 15).

The revised supervisory framework distinguishes between the general risk-management expectations and the additional aggregate-monitoring and adjustment expectations applying to firms above the de minimis threshold. SS2/26 paragraphs 1.3 and 1.4 specify which supervisory expectations are switched off for smaller lenders and when they become applicable as lending volumes increase: paragraph 1.3 switches off only paragraphs 2.4, 2.5 and 3.1 to 3.7 for de minimis firms, so the risk management expectations in paragraphs 2.1 to 2.3 are not switched off.

The instrument deletes rules 1.5 to 1.10, which set the old Condition A and Condition B tests based on credit volume and the number of contracts, and rule 1.1 now applies the Housing Part to a firm with a Part 4A permission that includes entering into a regulated mortgage contract as lender, subject to its remaining exception for firms with permission to effect or carry out insurance contracts as principal (PRA Rulebook, Housing Part, version from 28 October 2026). PS19/26 describes its de minimis edits as clarifying that the definition remains exactly the same as the previous rule, so a lender that sat outside the Housing Part under the old Condition B has a question worth putting to its supervisor before 28 October.

FG26/11 draws the line in a different form. Paragraph 11 asks every firm in its scope to determine, on an ongoing basis, whether its regulated mortgage lending exceeds the threshold, and paragraph 13 applies the high LTI limit provisions in paragraphs 17 to 23 only to firms above it.

Building a high LTI flow figure that matches the regulators’

The number rests on three definitions. A high LTI mortgage contract is a regulated mortgage contract under which the credit provided to an individual, or to individuals jointly, is or exceeds 4.5 times the individual’s or joint income at the time the firm assesses that income for the purpose of entering into the contract. High LTI flow is the percentage of all regulated mortgage contracts entered into in a set of four calendar quarters that are high LTI contracts (SS2/26 paragraph 1.2). And a regulated mortgage contract, for this purpose, disregards the five categories now listed in rule 1.11. FG26/11 spells out income as gross annual income, before tax and other deductions, that the firm takes into account to calculate the credit it will provide.

The data source is the FCA’s Product Sales Data. SS2/26 footnote 10 says the PRA uses PSD to calculate a firm’s high LTI lending, and SS2/26 chapter 4 says the aggregate is calculated from it. Mortgage lenders report regulated mortgage sales in PSD001 under SUP 16.11, by calendar quarter, within 20 business days of the end of each reporting period (SUP 16.11.3R). The FCA’s general product sales data page describes reporting completed transactions. For mortgage PSD001, however, SUP 16.11.5R also requires internal product transfers and internal remortgages to be reported, whether or not a new mortgage contract is entered into. SUP 16 Annex 21 specifies transaction dates for product switches and rate changes as well as mortgage completions and drawdowns.

That completion basis creates a timing gap reporting teams need to model. The Housing Part counts contracts “entered into”; PSD counts completions; and SS2/26’s first stylised example bases the first post-announcement measure on Q+7 completions. CP6/26 attributed the delay between an announcement and visible reductions to the gap between offers, completions and regulatory data submission. The final SS2/26 paragraph 3.5 says reductions are not expected to be accurately reflected in data until six subsequent quarters have passed.

Three classification calls deserve explicit tests in the extraction logic:

  • Further advances. Internal product transfers and further advances completed on or after 1 April 2021 must be reported in PSD001, so a firm’s submission file already holds further advances that the Housing Part disregards from 28 October. A measure built straight from that file without a filter counts contracts the regulators exclude, and the same applies to product transfers and other reportable transactions that create no new contract.
  • Remortgages. The exclusion covers only a re-mortgage where the credit does not exceed the amount outstanding under the previous mortgage, ignoring arrangement fees, professional fees and administration costs. A capital-raising remortgage falls outside that exclusion and should enter the high LTI calculation only if it is a newly entered, in-scope regulated mortgage contract and no other exclusion applies, including the exclusion for qualifying further advances.
  • Ported loans. The Housing Part’s further-advance definition requires the extra credit to be secured on the same property, and the FCA’s PSD mortgage FAQ separately says porting should not be reported as a further advance. A ported loan therefore has to clear the other exclusions on its own facts.

The internal metric should be reconciled to the firm’s PSD001 submissions, but the full PSD001 transaction population is not itself the denominator for high LTI flow. SUP 16.11.5R requires internal product transfers and internal remortgages to be reported even where no new regulated mortgage contract is entered into. Firms should first identify contracts actually entered into, using PSD001 transaction classifications and underlying origination records, then apply the Housing Part exclusions and the 4.5-times-income test. The resulting numerator and denominator should be reconciled to the submitted PSD001 records, including documented exclusions. Teams that already reconcile mortgage data for prudential returns, such as those covered in our UK FINREP reporting guide, will recognise the exercise, although PSD001 is FCA data governed by SUP 16.11. The FCA Glossary terms the Housing Part now borrows, retirement interest-only mortgage and lifetime mortgage, can be pulled alongside SUP 16.11 through the FCA Handbook API when the exclusion logic is documented.

Single-quarter aggregate, four-quarter firm measure

The main change between consultation and final policy is a split in measurement periods. CP6/26 proposed a single calendar quarter both for monitoring the aggregate and as the basis for each lender’s adjustment. Seven respondents criticised the single-quarter basis for adjustments, pointing to volatile pull-through from approvals to completions, seasonality and other policy changes such as tax incentives (PS19/26 paragraph 3.34). The regulators kept the single calendar quarter for the aggregate, as the most timely signal, and moved firms’ flows and adjustment expectations to a rolling four-quarter basis (PS19/26 paragraphs 1.5 and 3.38 to 3.41).

For firms, a four-quarter window is familiar: the deleted rule 2.1 measured each lender over a relevant period of the quarter and the three preceding it. The aggregate is where the measurement tightens. PS19/26 paragraph 3.32 describes the existing aggregate as a four-quarter rolling measure; six respondents warned that a single-quarter figure can be seasonal or volatile, and four of them asked to keep the rolling measure. The regulators’ answer sits in the trigger, which is a judgement: SS2/26 paragraph 3.5 ties published expectations to the aggregate being inconsistent with the limit “on a persistent basis”.

The PRA’s first publication covers four quarters on the single-quarter basis:

Quarter High LTI share of in-scope mortgages High LTI mortgages In-scope mortgages
2025 Q3 9.7% 21,910 226,330
2025 Q4 11.5% 26,790 233,590
2026 Q1 12.9% 25,600 199,210
2026 Q2 14.1% 29,240 208,090

The PRA’s notes say volumes are rounded to the nearest 10 mortgages, that only mortgages originated by firms above the de minimis threshold are included, and that the data are subject to revision. In-scope mortgages were 28% to 31% of all regulated mortgage sales in these quarters; the wider total includes all regulated mortgage sales, such as house purchase and remortgages, as reported in PSD.

The PRA will publish the 2026 Q3 aggregate, with the supporting volume data, in 2026 Q4. If revisions to reported data materially change the aggregate, the PRA will publish an updated figure (SS2/26 paragraph 4.5).

Revisions matter for an individual lender too. SS2/26 paragraph 3.6 sets the starting point for any reduction as the amount by which the firm’s four-quarter flow exceeded 15% in the data available prior to announcement. The SS does not say whether a PSD001 correction submitted after an announcement resets that starting point.

Inside the fractional adjustment, using the PRA’s own paths

An adjustment starts with a judgement. If the PRA and FCA judge the aggregate inconsistent with the 15% limit, the PRA may set expectations for firms whose four-quarter flow exceeds 15%, and the FCA issues what FG26/11 calls temporary supplemental LTI guidance (SS2/26 paragraph 3.3; FG26/11 paragraph 19). Neither text defines “persistent” as a number of quarters, and PS19/26 paragraph 3.31 records a respondent welcoming the regulators’ scope to judge that an aggregate above 15% needs no adjustment.

The size of the cut is a fraction of the firm’s excess over 15%. The fraction is calculated at the point of announcement for each successive future quarter, and each quarter’s expected adjustment applies to the reduced excess expected in the previous quarter, so the steps shrink over time. The PRA sets the fraction using the latest available data, supervisory intelligence and known external market factors (SS2/26 paragraph 3.6). PS19/26 paragraph 3.37 records a lender asking whether each quarter’s reduction would be rebased on its actual excess or stay anchored to its excess at announcement; the amended paragraph 3.6 answers that the reduction is calculated at announcement for all successive quarters (PS19/26 paragraph 3.45).

SS2/26 gives two stylised examples. In the first, the aggregate drifts gradually out of line, the Q0 figure is published in Q+1, and the PRA asks firms above 15% to close one sixth of their excess each quarter, with the first measure based on Q+7 completions. A firm at 17.5% has an excess of 2.5 percentage points; one sixth of that is about 0.42, giving an expected 17.1% at Q+7, 16.7% at Q+8, 16.4% at Q+9 and 16.2% at Q+10. In the second, the aggregate moves sharply and the fraction is one third: a firm at 20.0% on a rolling four-quarter basis faces expected levels of 18.3%, 17.2%, 16.5%, 16.0%, 15.7% and 15.4% in successive quarters. Both examples end with the PRA withdrawing its expectations once the aggregate is no longer considered inconsistent with the limit, after which the example firm may increase its future flow in line with its own risk appetite. In the first example that follows the Q+9 aggregate, published in Q+10; in the second it follows the Q+6 aggregate, published midway through Q+7.

Three readings of the mechanism fail against the text. The cut is a share of the lender’s own flow: PS19/26 paragraph 3.29 says adjustments are expressed as the share of high LTI lending within a lender’s own flow, not nominal volume or position relative to the market, and the regulators do not regard them as restricting competition for market share. Existing approved offers stand, because the expectation applies only to future lending decisions (SS2/26 paragraph 3.5; FG26/11 paragraph 21). And the fraction is the same whatever a lender’s size, business model or risk quality. Respondents asked for tiering or risk-based differentiation; the regulators declined, citing complexity and fairness, and pointed to the de minimis threshold as the accommodation for the smallest lenders (PS19/26 paragraphs 3.25 and 3.26).

The lag is the planning horizon. CP6/26 had said reductions would not be accurately reflected in data until three subsequent quarters had passed; the final SS2/26 says six. On that timetable, criteria tightened in an announcement quarter are not expected to register fully in the regulators’ measure for about a year and a half.

Risk appetite, board oversight and MI in SS2/26

SS2/26 chapter 2 sets what the consultation called broad qualitative expectations. PS19/26 paragraph 3.15 says there is no one-size-fits-all approach and points firms to the regulators’ existing approaches to supervision and governance; two respondents who asked for more detailed board expectations received that answer. The concrete content sits in four paragraphs:

  • Paragraph 2.2: a risk management framework and compensating lending controls for high LTI lending, consistent with the Risk Control Part of the PRA Rulebook, applied at firm or group level.
  • Paragraph 2.3: risk appetite limits on high LTI lending; where they are absent, limits set and monitored for current and expected future flow, concentrations and high-risk segments, and mortgage performance, with management information that is meaningful and well-targeted and informs board discussion.
  • Paragraph 2.4: above-threshold firms monitor the published aggregate and hold assurance that they can adjust future flow if needed.
  • Paragraph 3.3: the firm’s board oversees any action taken to meet adjustment expectations.

PS19/26 paragraph 1.6 confirms that the FCA’s governance and adjustment expectations sit alongside its SYSC requirements, and paragraphs 3.15 to 3.18 describe the regulators’ proportionate approach to governance and supervisory engagement. PS19/26 paragraph 3.16 adds that firms already writing high LTI mortgages should have appropriate measures in place, and that a firm wanting to go above 15% may consider enhancing its controls to assure itself it can make future reductions.

Expected future flow is the demanding item for data teams. The regulators’ measure counts completions, and SS2/26 paragraph 3.5 says reductions are not expected to be accurately reflected in data until six subsequent quarters have passed following an announcement, so an MI line taken from the last PSD001 submission tells the board where the firm was. A forward view needs the offer and approval pipeline converted into expected completions by LTI band, and respondents described exactly that pull-through as volatile (PS19/26 paragraph 3.34). Firms on the interim arrangements have been required to provide high LTI projections and monthly data on mortgage approvals and completions (CP6/26 paragraph 2.33), which gives them a starting dataset. For other lenders, SS2/26 sets the expectation without prescribing a method.

When the regulators do expect a reduction, PS19/26 paragraph 3.43 says they expect to discuss with the firm how it intends to comply, through regular engagement, covering for example changes in risk appetite limits, lending criteria and internal monitoring. Mortgage performance data also feeds expected credit loss work, where the PRA raised data governance points in its September 2026 letter, covered in our note on the PRA IFRS 9 ECL letter.

Telling supervisors: a conversation at the PRA, a notification at the FCA

The two regulators phrase the step before crossing 15% differently. SS2/26 paragraph 2.3 says that where a firm makes risk management changes in order to increase its high LTI flow above 15%, the PRA expects it to discuss these changes as part of regular engagement with supervisors. PS19/26 paragraph 3.17 recalls the consultation proposal that a lender intending to change its strategy to take high LTI flow above 15% should notify its relevant regulator, and adds that this does not preclude notifying lesser strategy changes the regulator would reasonably expect notice of, consistent with the PRA Fundamental Rules and PRIN 2.1. Paragraph 3.18 says the regulators largely expect to discuss high LTI lending through existing, routine supervisory engagement, case by case. SS2/26 paragraph 2.5 lets the PRA ask to discuss a reduction a firm is making under chapter 3.

For FCA-only lenders, FG26/11 paragraph 18(a) says a firm should notify the FCA if it intends to change its lending strategy in order to increase its high LTI flow above 15%. PS19/26 paragraph 1.3 explains that firms may exceed 15% while the aggregate remains consistent with the FPC’s limit, but may be expected to reduce their flow if the aggregate becomes inconsistent with that limit. Where a firm has not acted in accordance with the guidance or any temporary supplemental LTI guidance, FG26/11 paragraph 31 says the FCA may consider using its supervisory powers, for example its power under section 55L of the Financial Services and Markets Act 2000 to require a firm to cease entering into high LTI mortgage contracts.

Measurement runs on PSD001 and notification travels through supervisory contact; none of PS19/26, SS2/26 or FG26/11 creates a new regulatory return. A monthly feed built for the modification by consent belongs to the interim regime. CP6/26 paragraph 2.33 said the regulators did not propose to collect the interim projections and monthly approval and completion data under the new policy, and that firms would keep sharing it until the modification or individual guidance ceased to have effect. PS19/26 lists no change to that point among its changes to draft policy, and the interim directions fall away on 28 October 2026.

Calibration and other questions PS19/26 leaves open

Several of the loudest consultation responses were about things the package does not touch. Respondents argued that the 4.5 times threshold is out of date, suggested raising it to 5 times or removing the flow limit, and asked for the de minimis threshold to rise to £250 million, £500 million or £1 billion, or to be graduated. The regulators treated all calibration points as outside the consultation and passed them to the FPC for its next review of housing tools (PS19/26 paragraphs 2.11, 3.54, 3.55 and 3.58). PS19/26 paragraph 3.26 notes that the FPC proposed, in its November 2024 Record, to review the de minimis threshold regularly.

Two respondents wanted long-term fixed-rate products excluded from the limit. The regulators kept the scope of mortgages as consulted, with only further advances and retirement interest-only contracts newly excluded (PS19/26 paragraphs 3.4 and 3.5). Comments linking the policy to wider housing and growth policy were noted, and the FCA considered relevant feedback within its separate Mortgage Rule Review, CP26/18 (PS19/26 paragraphs 3.56 and 3.58). A request to share lessons from the interim waiver was ruled out of scope.

The package’s only rule instrument amends the Housing Part. Mortgage credit risk capital moves on other tracks, such as the Pillar 2A credit risk changes in PS15/26, effective 1 January 2027 and covered in our note on the PRA Pillar 2A review Phase 1. Whether the FPC changes the 4.5 times or 15% parameters, and when, is the open question PS19/26 leaves behind.

Frequently Asked Questions

Our group has a PRA-authorised bank and a separately authorised FCA lending subsidiary. Which document applies to the subsidiary?

FG26/11 paragraph 5 excludes a subsidiary undertaking of a bank or building society with permission to lend on regulated mortgage contracts, so the FCA guidance does not reach it. PS19/26 paragraph 2.2 says PRA rules require relevant firms to apply the rules at UK subsidiary level to firms not already in scope, which brings the subsidiary in through the PRA parent. If both entities are above the de minimis threshold, flow is measured at group level; an entity below the threshold does not contribute to the group figure.

We are below the de minimis threshold but growing quickly. When would adjustment expectations start to apply?

From the start of the second quarter following the end of the final quarter relevant to the determination that the firm exceeds the threshold (SS2/26 paragraph 1.4; FG26/11 paragraph 14). On that wording, a determination resting on quarters ending 31 December would bring paragraphs 2.4, 2.5 and chapter 3 into play from 1 April. SS2/26 does not say how a firm crossing the threshold during a live adjustment period should set its starting excess, which is worth raising with the supervisor if it happens.

We are a credit union with a small mortgage book. Is FG26/11 or SS2/26 the relevant text?

SS2/26. Credit unions are among the PRA-authorised firms listed in PS19/26 paragraph 2.2 and are excluded from FG26/11 by its paragraph 5. Below the de minimis threshold, SS2/26 chapter 3 and paragraphs 2.4 and 2.5 do not apply.

Will the PRA tell us our own high LTI flow?

PS19/26 does not commit to it. Respondents asked for lender-specific metrics (paragraph 3.50); the regulators agreed to publish additional aggregate data, the in-scope completed mortgage volume and its share of all completions, while noting a duty not to reveal confidential information about individual lenders (paragraphs 3.51 and 3.52). The FCA says it will use product sales data to monitor individual firm flows as part of supervisory engagement (FG26/11 paragraph 29), and since the regulators work from PSD, a rebuild from the firm’s own PSD001 submissions is the nearest equivalent it can hold.

If our flow falls to 15% before the expectations are withdrawn, do we keep reducing?

SS2/26 paragraph 3.6 illustrates an adjustment continuing until a firm’s flow is equal to or below 15%, or the expectations are amended or withdrawn, whichever occurs sooner. Paragraph 3.5 also expects firms below 15% to remain below that level while adjustment expectations apply.

Does any of the older FCA guidance on the LTI limit still apply?

No. FG26/11 paragraph 4 revokes and replaces the guidance issued on 1 October 2014 (FG14/8) and revised on 27 February 2017 (FG17/2) and 11 July 2025 (FG25/4), with effect from 28 October 2026 under PS19/26 paragraph 2.13.

Key Takeaways

  • From 28 October 2026, replace the blanket firm-level 15% cap with a firm-set risk appetite limit and controls for any subsequently announced adjustment. During an adjustment, firms at or below 15% are expected not to increase above that level. If an adjustment is announced, firms above the de minimis threshold whose four-quarter flow exceeds 15% are expected to follow the regulators’ published, phased reduction path for future lending, rather than immediately reducing their flow to 15%.
  • Reconcile PSD001 to the population of newly entered, in-scope regulated mortgage contracts. Exclude reportable product switches and other variations that do not create a new contract, then apply the Housing Part exclusions, including further advances, retirement interest-only mortgages and the existing exclusions, before calculating high LTI flow.
  • Plan for reductions in individual high LTI flow not to be accurately reflected in regulatory data until six subsequent quarters have passed after an announcement. Firms are nevertheless expected to adjust future lending decisions promptly; SS2/26’s illustrative paths place the first measured reduction expectation at Q+7 completions.
  • Clean PSD001 errors before they matter: an adjustment’s starting excess is taken from the data available prior to announcement.
  • FCA-only lenders: FG26/11 paragraph 18(a) expects a firm to notify the FCA before changing its lending strategy to take high LTI flow above 15%. PRA firms: raise the same change in regular supervisory engagement.
  • PRA lenders below the de minimis threshold: confirm with the supervisor how the revised Housing Part application conditions affect them.
  • Stop planning the interim monthly approvals and completions feed as a permanent process; it is tied to arrangements that end on 28 October 2026.

Sources and References

  • PRA and FCA, PS19/26 (FCA PS26/20) High loan to income lending (14 October 2026): bankofengland.co.uk
  • PRA, SS2/26 High loan to income lending (14 October 2026, effective 28 October 2026): bankofengland.co.uk
  • PS19/26 Appendix 1, PRA Rulebook: CRR Firms: Non-CRR Firms: Housing (Amendment) Instrument 2026 (PRA2026/27): ps1926app1.pdf
  • PRA Rulebook, Housing Part, version from 28 October 2026: prarulebook.co.uk
  • PRA and FCA, CP6/26 (FCA CP26/12) High loan to income lending (1 April 2026): bankofengland.co.uk
  • PRA, High loan to income (LTI) lending: aggregate flow publication: bankofengland.co.uk
  • Bank of England, Financial Policy Committee Record, July 2025: bankofengland.co.uk
  • FCA, FG26/11 The Financial Policy Committee’s recommendation on loan to income ratios in mortgage lending: General Guidance (October 2026): fca.org.uk and fg26-11.pdf
  • FCA Handbook, SUP 16.11 Product sales data reporting: handbook.fca.org.uk
  • FCA Handbook, SUP 16 Annex 21 Product sales data (mortgage data fields, date of mortgage transaction): handbook.fca.org.uk
  • FCA, Product sales data: fca.org.uk
  • FCA, Product sales data policy and business FAQs: mortgages: fca.org.uk
  • PRA, PS15/26 Pillar 2A review: Phase 1 (May 2026, effective 1 January 2027): bankofengland.co.uk
  • PRA, Thematic feedback on accounting for IFRS 9 expected credit losses (ECL), letter to chief financial officers (30 September 2026): bankofengland.co.uk
  • FCA, CP26/18 Mortgage rule review: supporting first-time buyers and underserved consumers (9 June 2026; referenced in PS19/26): fca.org.uk

Getting to 28 October with one high LTI dataset

The policy moves the hard number out of the rulebook and into a quarterly publication, a supervisory conversation and an adjustment fraction the PRA would publish if the aggregate became inconsistent with the FPC’s limit. A lender’s exposure to that fraction depends on two things it controls now: how far above 15% its four-quarter flow sits in the data the regulators hold, and how quickly its pipeline can turn a tightening of criteria into lower completions.

The work before commencement is a single in-scope dataset of newly entered contracts, built from origination records and PSD001 classifications with the rule 1.11 exclusions applied and reconciled to what the firm submitted, and a board paper that sets the high LTI risk appetite limit against it. The next scheduled quarterly publication is the PRA’s 2026 Q3 aggregate, due in 2026 Q4.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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