Borrowers with substantial wealth are often the hardest to place. A salaried employee on a predictable income fits a high street affordability model without difficulty. A founder drawing modest salary and large dividends, a fund partner with carried interest, or an investor whose income arrives as distributions and realisations does not. The paradox of high-net-worth lending is that the wealthier the balance sheet, the less likely the automated system is to understand it.
This article sets out how the two ends of the market actually differ, what the FCA high-net-worth exemption does and does not do, and how cases at the GBP 1 million and above level are typically structured in 2026.
Where the high street stops
Mainstream lenders underwrite to a standardised affordability calculation: evidenced income, a stress rate, and a maximum loan-to-income multiple. Most will consider complex cases up to somewhere in the region of GBP 1 million to GBP 2 million, and will take limited company directors’ salary and dividends, sometimes retained profit. Beyond that, or where income is genuinely non-standard, cases start falling outside policy rather than failing on merit.
Typical sticking points include bonus and commission treated at a heavy discount or excluded entirely, foreign currency income, carried interest and deferred compensation, share vesting schedules, income from trusts, and applicants with significant assets but low declared income. None of these indicate weak credit. They indicate that the borrower does not fit the template.
What private banks do differently
Private banks and specialist lenders underwrite the individual rather than the payslip. Broadly, private banks operate from around GBP 3 million upwards, with specialist lenders active from roughly GBP 1 million. The underwriting is relationship-led and manual, and the assessment looks at the whole position: liquid investments, property holdings, business interests, pension provision, historic income patterns and the trajectory of the client’s wealth.
That produces structures the mainstream market cannot offer:
- Interest-only over longer terms, with a repayment strategy based on asset realisation rather than a repayment vehicle in the conventional sense.
- Terms extending past normal retirement age, where the asset base supports it.
- Assets under management arrangements, where the bank offers keener pricing or a higher loan-to-value in exchange for investable assets placed with it. This has a real cost and should be assessed on total return, not headline rate.
- Securities-backed lending, using an investment portfolio as security rather than, or alongside, the property.
- Multi-currency borrowing, where income and assets are denominated other than in sterling.
The trade-off is process. These are committee-underwritten cases that require a properly assembled file, and they move at the pace of a human reading documents rather than a system scoring them.
The FCA high-net-worth exemption, accurately stated
The exemption applies where the borrower has annual net income of at least GBP 300,000, or net assets of at least GBP 3 million, excluding the primary residence and pension provision. Where it applies, and where the borrower elects to use it, the lender may disapply certain standard affordability requirements and underwrite on a bespoke basis.
Two points are frequently misunderstood. First, the exemption is not a product; it is a regulatory route that permits different underwriting, and lenders still apply their own credit standards. Second, using it means giving up some of the protections that apply to standard regulated lending. That is a considered decision, not a formality, and a borrower should understand exactly what is being disapplied before electing to proceed on that basis.
Portfolio and structural considerations
High-net-worth clients rarely present a single transaction. The residential purchase usually sits alongside an investment portfolio, sometimes held through one or more limited companies, and occasionally involving overseas property or non-UK residence. Those elements interact.
Where property is held corporately, the lending market, pricing and tax treatment differ from personal ownership, a comparison we set out in buy to let mortgages in 2026: personal vs limited company. Clients living or working abroad face a further layer of lender selection, covered in our guide to expat buy to let mortgages. Non-UK residents should also note the additional 2% stamp duty surcharge that applies on top of standard rates and, where relevant, the 5% additional property surcharge.
Where the requirement is to release capital without disturbing an advantageous existing first charge, a second charge facility can be more efficient than a full remortgage. We examined when that arithmetic works in second charge mortgages in 2026, and our secured loans page sets out the products available.
Preparing a private bank case
The quality of the submission has a disproportionate effect on the outcome. A strong file generally contains:
- A clear statement of net worth with supporting valuations and statements.
- Three years of accounts or tax returns, with an explanation of any material movement.
- Documentation for non-standard income: partnership agreements, vesting schedules, carry allocations.
- Evidence of the source of wealth, which is now a substantive underwriting requirement rather than a formality.
- A coherent account of the repayment strategy where the loan is interest-only.
Presenting the case without that material, and answering questions reactively, tends to produce a slower process and a more cautious offer.
Speak to us
Giles Finance advises clients on large and complex mortgage cases, working with private banks, specialist lenders and mainstream lenders according to where the case sits. Our earlier overview, high net worth mortgages in the UK, covers the product landscape in more detail, and our residential mortgages and remortgages page covers the regulated side of what we do. Landlords with substantial holdings may also find our buy-to-let and portfolio landlord hub useful. Clients in south west London can reach our Putney mortgage broker office directly.
Call 0208 088 2211 or use our contact page for a confidential discussion.
YOUR HOME MAY BE REPOSSESSED IF YOU DO NOT KEEP UP REPAYMENTS ON YOUR MORTGAGE.
Buy-to-let mortgages and most lending to limited companies are not regulated by the Financial Conduct Authority; where such lending is secured on property, YOUR PROPERTY MAY BE REPOSSESSED IF YOU DO NOT KEEP UP REPAYMENTS. Tax treatment depends on individual circumstances and may change; take advice from a qualified tax adviser or accountant before acting.
Giles Finance is a trading style of Giles Finance & Consultancy Services, authorised and regulated by the Financial Conduct Authority (FRN 726857).