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Can a later drawdown be a separate complaint?

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UKPublished 6 October 2026 · Written by BuyMeWhiskey Editorial Team · How we check facts

A later lifetime-mortgage drawdown can potentially be a separate complaint issue, but it does not automatically restart the time limit for an earlier mis-sale complaint. What matters is what went wrong at the later transaction and when you knew, or should have known, about it.

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Set out the dates of the original mortgage and every later drawdown before making a complaint, then ask the firm to confirm which event it believes your complaint concerns.

How to complain about a financial service – FCA

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Start with the event you are actually complaining about

A lifetime mortgage can involve more than one financial event: the original recommendation, the mortgage being completed, a later drawdown, a further advance, a change in interest terms, or a later repayment decision. The fact that the account has one overall mortgage number does not by itself tell you whether a later transaction is a separate complaint issue.

The useful question is: what did the firm do in the event you say was wrong? If the complaint is that the original lifetime mortgage was unsuitable in 2015, a later drawdown does not automatically restart the time limit. If the complaint is specifically about advice or information given before a separate drawdown, that later event may need to be considered on its own facts.

An ombudsman complaint is not the same as a court claim

FCA complaint rules and Financial Ombudsman Service time limits are not the same thing as a legal limitation period for court proceedings. This page is about the regulated complaint route. Court claims can involve different limitation rules and should be checked with a solicitor if you are considering litigation.

For complaints to a financial business, the FCA says you normally have 6 years from the problem, or, if later, 3 years from when you became aware, or ought reasonably to have become aware, that you had cause to complain. The Financial Ombudsman Service uses the same broad framework and can allow exceptions in some circumstances.

What a 2015 drawdown means in 2026

A 2015 transaction is now well outside the normal six-year period. That does not mean every possible complaint is automatically impossible, because the later-awareness limb can matter. It does mean you should not assume that calling a 2015 drawdown a "separate actionable event" will make an old complaint timely.

For a complaint made in October 2026, the firm and, later, the ombudsman will want a clear chronology: the original advice date, completion date, each drawdown date, what was said at each stage, when statements or illustrations arrived, and when you first believed something may have gone wrong.

Lifetime mortgages are within the ombudsman framework

The Financial Ombudsman Service specifically deals with complaints about equity release, including lifetime mortgages. It says it looks at complaints about issues such as suitability, vulnerability, early repayment charges and whether the amount due to repay is fair. It also says it applies the regulatory and legal standards that were in force at the time of the event being complained about.

That last point is important for a historic case. A complaint about a 2015 sale should not be assessed simply by reading today's consumer guidance and assuming the same requirements applied then.

Evidence that can separate a later drawdown from the original advice

The original suitability or advice report.
The offer and mortgage terms from the initial completion.
The date and purpose of each later drawdown.
Any later advice, illustration, call note or correspondence.
Statements showing how interest and the balance changed.
Evidence of when you first discovered the issue you now complain about.

A separate drawdown is stronger as a distinct complaint point when the alleged problem is tied to something that happened at that drawdown rather than simply being the same original sale repackaged in different words.

What to do now

Complain to the lender or adviser first and set out the events separately. Ask the firm to identify which event it believes the complaint concerns and which time limit it says applies. Keep the complaint focused on facts rather than arguing the legal conclusion in the subject line.

If the final response does not resolve it, check whether the Financial Ombudsman Service can consider the complaint and what deadline applies to take it there. For a genuinely legal limitation question, get independent legal advice rather than relying on the ombudsman route alone.

Worked example

Illustrative chronology: A lifetime mortgage completed in July 2015 included a later drawdown in November 2015. In October 2026 the customer says the later drawdown should count as a separate actionable event.

Normal six-year complaint period measured from the July 2015 event would end in 2015 + 6 = 2021.
The November 2015 drawdown would ordinarily put its own six-year endpoint at 2015 + 6 = 2021 as well.
By October 2026, the earliest 2015 event is about 2026 − 2015 = 11 years old.
The question that could still matter is whether the customer became aware, or ought reasonably to have become aware, of the cause to complain later than the event itself. That three-year awareness limb is fact-specific.

So the chronology does not prove that the 2015 drawdown is a separate timely complaint. The safer approach is to identify exactly what happened at the drawdown and when the customer knew, or could reasonably have known, there was a problem.

Does a lifetime mortgage drawdown restart the complaint time limit?#

Not automatically. A later drawdown can be a separate transaction, but the complaint must still relate to a distinct problem connected with that event. Simply pointing to a later drawdown does not, by itself, reset the time limit for a complaint about the original lifetime-mortgage advice.

Can I complain about a lifetime mortgage from 2015 in 2026?#

A 2015 complaint is outside the normal six-year period, but the FCA and Financial Ombudsman Service also recognise a three-year period linked to when you became aware, or ought reasonably to have become aware, of cause to complain. Whether that saves an old complaint depends on the evidence and chronology.

Does the Financial Ombudsman cover lifetime mortgage complaints?#

Yes. The Financial Ombudsman Service deals with complaints about equity release, including lifetime mortgages. It can consider issues such as suitability, vulnerability, early repayment charges and the amount due, applying the rules and standards relevant to the event being complained about.

Should I complain to the lender or adviser first?#

Yes. Financial businesses normally have their own complaint process, and the FCA expects consumers to contact the firm first. Keep the complaint factual: set out the original sale, each drawdown, the issue you say occurred and the dates you discovered the problem.

What records should I get for a historic lifetime mortgage complaint?#

Ask for the advice or suitability report, mortgage offer, drawdown requests, illustrations, statements, call records and correspondence. The more clearly you can separate the original transaction from later drawdowns, the easier it is to explain what event the complaint is actually about.

Can a 2015 lifetime mortgage complaint go to court instead?#

Possibly, but a court claim is a different route from an ombudsman complaint and can involve different limitation rules. Because a historic case can turn on legal limitation, obtain advice from a solicitor before assuming the ombudsman time limits also govern a court action.

What if the complaint is about a later early repayment charge?#

That is a different issue from whether the original lifetime mortgage was suitable. The Financial Ombudsman Service specifically deals with lifetime-mortgage complaints about early repayment charges and assesses whether the business applied the relevant terms fairly in the circumstances. The dates of the drawdown, advice and discovery of the problem should be recorded separately in the complaint chronology.

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Sources

Figures were checked against these sources before publication. If a rule changes, we update the page and show the new date.

General information, not personal financial advice. Rules depend on your circumstances; check the official source or speak to a regulated adviser before acting.