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Ethical Finance

We Can Do Better.
We Must Do Better.

May 1, 2025
5 min read

An Open Letter to the Commercial and Business Finance Community

To the brokers, lenders, and professionals in the commercial and business finance space – often referred to as the "unregulated loan" community – this is a heartfelt plea.

I didn't begin my career as a mortgage adviser or finance broker. I entered this world as an accountant – someone who saw first-hand how clients were being underserved by the brokers and advisers they trusted. So, we did something about it. We built an FCA-regulated mortgage brokerage to support our accountancy clients and complement our professional services. Today, we proudly continue to advise on regulated mortgages, bridging loans, and equity release.

But my passion has always been supporting businesses and entrepreneurs – and that journey naturally led me into what is commonly known as the "unregulated space."

Let's clarify what that means.

In the UK, "regulated" finance products are overseen by the Financial Conduct Authority (FCA), with strict rules around advice, affordability, and consumer protection – typically applying to residential mortgages and personal borrowing. In contrast, commercial lending – including many types of bridging finance, business loans, and property investment lending – often falls outside of this regulatory framework. Hence, it's called "unregulated."

But unregulated should never mean unprincipled.

The purpose of this open letter is to speak directly to the industry I've grown to love. Over the last 12 months, I've seen too many cases where clients have been placed into inappropriate or unaffordable loans. Bridging facilities with no viable exit. Finance with excessive fees. Deals structured in a way that simply wasn't in the borrower's best interest – and in some cases, appeared to have been written purely to close a deal and generate commission, regardless of consequence.

Let's be honest: some of these loans should never have been written.

We are better than this.

This space – the "unregulated" market – gives us freedom, creativity, and agility. But with that freedom comes responsibility. Just because a product is unregulated doesn't mean we operate without standards. In fact, it should mean we hold ourselves to a higher one. We must regulate ourselves.

My plea to this community is simple: treat customers fairly. Do the due diligence. Make sure the deal works for the client – not just for the broker or the lender. Because if we don't, regulators will intervene. And when they do, it won't just be businesses like ours that suffer. Clients will too.

I've seen the impact of heavy-handed regulation – how it can limit choice, slow down solutions, and stifle innovation. But if we fail to act now and raise standards ourselves, we invite that very outcome.

It's been encouraging to see organisations like the National Association of Commercial Finance Brokers (NACFB) working hard to promote responsible lending and support brokers and lenders in raising standards across the unregulated space. Their efforts to build a more transparent and ethical industry are welcome – but there is still more to do. And we all have a part to play.

So let's act.

Let's raise the bar.

Let's lead with integrity.

We can do better. We must do better.

Maxim Cohen

About the Author

Maxim Cohen

Maxim Cohen is the Chief Executive of The UK Finance Group, with over 20 years of experience in the financial services sector. A practising accountant, he is also a qualified mortgage adviser, finance specialist, and a Chartered Member of the Chartered Institute for Securities & Investment (CISI).

As the founder of multiple finance brands including The Financier™ and Finance Rabbi, Maxim combines ethical financial principles with strategic business advisory, connecting capital to opportunity across the UK, US, and Middle East.

בזכות ר' ישעיה בן ר' משה זצ"ל

Maxim Anthony Cohen is an approved person on the FCA register (REF MAC01431) and certified and assessed by the firms UK Finance Group (a trading style of HMB Finance Group Ltd (FCA 752970)) & The UK Adviser Ltd (FCA 798920) which are authorised and regulated by the Financial Conduct Authority (FCA) respectively.

Buy-to-Let Mortgages, Commercial Loans and Business Finance are not regulated by the FCA. Your home or assets may be repossessed if you do not keep up repayments on your mortgage or other loans secured on them.

The Financier Ltd is registered in England and Wales (Company number 11409784). Registered office: 193a Ashley Road, Hale, Altrincham, United Kingdom, WA15 9SQ.

The Financier Ltd is a 100% subsidiary of The Financier LLC, a Delaware Limited Liability Company (Correspondence address: PO Box 19901, 8 The Green, Dover, Delaware, United States).

© 2026 The Financier Ltd. All rights reserved.

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