To automate a mortgage fact find, capture it from evidence you already have, such as the client's documents, an online questionnaire and the advice meeting, and have the adviser check every value before it is relied on. MCOB still expects the adviser to consider all the relevant facts, so automation changes who does the typing, not who is responsible for the fact find.
What the rules expect of a fact find
There is no official FCA fact-find form. MCOB 4.7A requires advice to be suitable for the customer's needs and circumstances. In its thematic review of mortgage advice, TR15/9 (July 2015), the FCA explained that a firm can base its assessment on the facts the customer discloses, but that the adviser "must consider all relevant facts about the customer which they are aware of, or should reasonably be aware of" (paragraph 4.20, referring to MCOB 4.7A.5R).
That sentence is the test for any automation. If a payslip in the file shows overtime and the fact find shows basic salary only, the adviser was aware of the overtime, whether or not anyone typed it in. A tool that reads the documents can close that gap. A tool that fills fields nobody checks can widen it.
The parts you can automate
- Client questions answered before the meeting. An online form the client completes on their phone gets personal details, address history, dependants and commitments in without anyone keying them.
- Figures read from documents. Payslips, P60s, SA302s, bank statements, mortgage statements and ID hold most of the numbers a fact find needs. Software can read them and propose each value with the page it came from.
- Details from the meeting. A transcript of the advice meeting can suggest answers, such as the client's priorities or a planned career break, that never appear on a document.
- Data you already hold. On a remortgage or a further advance, last time's fact find is the starting point, and only what has changed needs asking again.
- Chasing what is missing. Once the fact find knows a field is empty or a document is out of date, the request to the client can be drafted automatically.
The parts that stay with the adviser
- The client's priorities and the reasons behind them. The FCA's review found the best firms probed and challenged customers when they expressed conflicting preferences (TR15/9, paragraph 4.21). Software can record what was said; it cannot have that conversation.
- Vulnerability. Noticing that a client is struggling, and deciding what to do about it, is a judgement, not a field.
- Conflicts between sources. When the payslip, the bank statement and the client's own answer disagree, the adviser decides which is right and records why.
- The decision to accept each value. Nothing proposed by software should become part of the fact find until the adviser has accepted it.
How to set it up
- Start from your network's fact find, or your own, and map each section to where its answer usually comes from: the client, a document, or the meeting.
- Send the client a short questionnaire for the sections only they can answer, and a document request for the rest, at the same time.
- Let software read the documents and the meeting, and propose values against the fact find with a source for each.
- Have the adviser review each section, accept or correct each value, and resolve any conflicts before the advice.
- Lock the version the advice was based on, with its date and sources, and keep it with the suitability record.
Be careful not to automate your way into a longer fact find. TR15/9 describes a firm whose "detailed systems-driven fact-finding" produced "an excessively long, disengaging process", with the system prompting "numerous unnecessary questions". The firm removed them. The aim is fewer questions for the client, not more fields because the software has room for them.
What to check before you trust it
- A source behind every value. You should be able to open the document or the transcript line a figure came from. A value with no source has to be checked by hand, which removes the point.
- The basis of each figure. Gross or net, monthly or annual, salary or dividends: a tool that reads the number but loses the basis creates the errors it was meant to remove.
- Your own paperwork. Test it with real, messy documents from recent cases, with your client's data handled under your normal controls, not with a vendor's clean sample pack.
- Where the data goes. If documents are processed by an AI service, your privacy notice must say so, and the vendor will be your processor under a written contract, as UK GDPR Article 28 requires.
- No decision without a person. UK GDPR Article 22 restricts decisions with legal or similarly significant effects made solely by automated means. A fact find that an adviser reviews and accepts keeps a person in the decision.
Keeping the record
MCOB 4.7A.25R requires a record of the customer information the firm relied on and of why the advice was suitable, and MCOB Schedule 1 gives three years from the advice as the retention period; your network may require longer. An automated fact find makes that record stronger only if it keeps the version, the date and the source of each value, so that a reviewer years later can see what the adviser knew and where it came from.
See a finished fact find, produced for a fictional client. Specimen fact find.