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Cream Financial Solutions has proposed four steps to help improve UK protection take-up: strengthen referrals to specialist advisers, raise awareness through personal stories, make client conversations more relevant, and explore spreading commission over time. The plan is the firm’s response to the Financial Conduct Authority’s call for meaningful industry progress; it is not an FCA rule or an FCA-endorsed programme.
What is Cream Financial Solutions’ four-point plan?
In a report published on 1 October 2026, Mortgage Solutions said Cream managing director Simon Smith outlined four actions firms could take to address the protection gap. The proposals cover how people are reached and advised, as well as how advisers are paid.
- Build stronger referral routes. Mortgage advisers who lack capacity to give protection advice, or face a case involving complex underwriting, could refer a client to a protection specialist or invest in dedicated in-house resources.
- Promote the personal reasons for cover. Cream said it would run a social-media awareness campaign informed by work from the Protection Distributors’ Group. It would focus on why people may value protection, such as supporting family or income, rather than leading with product names. Renters, self-employed people and others less likely to speak with a mortgage adviser were among the intended audiences.
- Start conversations with the client’s circumstances. Rather than opening with labels such as “income protection” or “critical illness cover”, advisers would ask about a client’s family, income, children, plans and ambitions. This is a suggested way to make discussions more relevant; it does not mean a particular policy is suitable for every person.
- Explore a hybrid commission model. Cream suggested that firms could choose how much commission to receive upfront and how much to receive over time as premiums are paid. The proposal is intended to reduce the significance of payment timing as an incentive, but it has not been adopted as a market-wide change.
Smith described protection advice as a specialist discipline alongside mortgage advice. The referral proposal is therefore aimed at making specialist help available when an adviser cannot give a case the time it needs, not at suggesting that mortgage advisers as a group are unqualified to discuss protection.
Why has the FCA called for progress?
Mortgage Solutions reported on 21 September 2026 that the FCA’s final Pure Protection Market Study report gave the market 12–18 months to demonstrate meaningful progress on take-up and consumer outcomes. This was a timeframe for industry progress, not a statutory deadline imposed by a new rule. The report said the regulator would work with stakeholders and retained the option of supervisory or enforcement action where needed; the coverage said it did not introduce a market-wide measure at that point.
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The FCA findings below are reported by Mortgage Solutions rather than independently checked against the underlying study in this article. Its coverage attributed the protection gap to factors including low awareness and understanding, consumer biases, friction in the customer journey, complex underwriting and limited product availability for people with complex needs. It also said the FCA saw potential switching risks from commission structures but did not find enough evidence in the study to justify market-wide intervention on unnecessary switching.
- 58%: Mortgage Solutions reported that the FCA study found 58% of adults had no protection.
- 59%: The Intermediary reported that 59% of adults without protection had never considered it. The precise population definition and methodology are not established here.
- 12–18 months: Mortgage Solutions reported this as the FCA’s timeframe for meaningful progress, not a guarantee that a new rule would follow at a specified date.
How could the proposals work in practice?
Referral pathways: the quickest operational change
A firm can assess whether its advisers have the time and capability to handle a client’s protection needs. Where they do not, Cream’s proposal is to make a clear referral to a specialist or add dedicated internal capacity. The point is continuity of access to advice, especially when underwriting is complex; a referral alone does not guarantee a suitable outcome.
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Awareness: reach people before a product discussion
The planned campaign would emphasize the life circumstances protection may relate to, rather than assume that audiences already understand policy terminology. Cream’s reported target groups include renters and self-employed people, as well as people who may not normally encounter a mortgage adviser. The proposal does not establish that a campaign has already changed take-up.
Client conversations: needs before labels
Questions about dependants, income and plans can help establish what a client wants to protect before an adviser discusses possible products. The proposal is about how to begin a conversation, not a recommendation that everyone needs the same cover. Suitability still depends on individual circumstances and advice.
Commission: a proposal to change payment timing
Mortgage Solutions reported Cream’s rationale that advisers may face commission clawback if a policy is cancelled within a specified period, while a fresh upfront payment may be available after that period. Cream argued that paying some commission over time could reduce the incentive created by that timing. The coverage does not establish a proposed commission split, a timetable for adoption, or evidence that the model has been implemented across the market.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What other industry work did the FCA report?
A separate Mortgage Solutions report on 21 September 2026 described FCA work with the Association of Mortgage Intermediaries (AMI), the Money and Pensions Service (MaPS), the Digital Property Market Steering Group (DPMSG) and the Protection Distributors’ Group (PDG). As reported, AMI’s work included adviser confidence and more consistent discussions; MaPS and DPMSG were to encourage people to consider protection at life and housing milestones; and PDG was to develop an awareness campaign for people less likely to take out cover. These are reported industry activities, distinct from Cream’s own four proposals.
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