CrestwellA fact find is the record of what you knew about a client when you gave advice. Most of the arguments about them are really arguments about that sentence: not whether a field was filled in, but whether the file shows you understood the client's circumstances at the moment you recommended something.
The FCA's mortgage conduct rules (MCOB) require an adviser to take reasonable steps to know the customer's needs and circumstances before advising, and to keep a record of the advice and why it was suitable. There is no official form. Networks and lenders each supply their own, which is why the same client can be asked the same question in four different shapes.
The sections a fact find needs
Across the templates in common use, the same eleven areas appear. The order varies; the content does not.
1. Personal details, for each applicant
Full legal name as it appears on ID, any previous name and the date it changed, date of birth, nationality and residency status, National Insurance number, marital status, contact details, and dependants with their dates of birth. Three years of address history, with the dates you moved, and whether you are on the electoral roll at the current one.
Two things here cause disproportionate trouble. A name recorded informally — Alex where the passport says Alexandra — is queried by every underwriter who reads the file against the ID. And an address history with a gap in it will stall a credit search, because the search cannot be run against a period nobody has accounted for.
2. Employment and income
Employment status, employer name and address, job title, time in role and time with the employer, gross basic salary, and any variable income — overtime, bonus, commission, shift allowance — recorded separately from basic, because lenders treat each differently and most apply a percentage to the variable part.
For self-employed applicants: trading style, shareholding, the accounting year end, and the last two or three years of net profit before tax or salary-plus-dividends, depending on how the business is structured. Record which basis the figures are on. A lender comparing an SA302 against a fact find that quietly mixed the two will ask.
3. Credit history and commitments
Adverse credit, honestly and specifically: defaults, CCJs, arrears, IVAs, bankruptcy, payday lending — with dates and amounts and whether they are satisfied. A client's recollection of "a small thing years ago" is frequently a default that is still inside a lender's window.
Then every current commitment: loans, credit cards, hire purchase, car finance, student loans, childcare costs, and any maintenance being paid. Balance, monthly payment, and whether it will be repaid before completion — the last one matters because it changes affordability, and a lender will ask for evidence of the repayment.
4. Budget and expenditure
The household's committed and discretionary spending. Most lenders overlay ONS-based figures, but they compare them against what the client declared and against the bank statements, so a budget that reads implausibly low invites questions rather than saving time.
5. The existing mortgage, where there is one
Lender, account number, outstanding balance, monthly payment, remaining term, repayment type, the current rate, and — the field most often left blank — the date the initial rate ends and any early repayment charge that applies before it. Those two decide whether a remortgage is advisable at all, and when.
6. The new borrowing
Purpose, purchase price or estimated value, deposit amount and its source, the loan required, the term in years and months, repayment method, and — for a part-and-part case — the split between capital-and-interest and interest-only. Where any part is interest-only, the repayment strategy has to be recorded and evidenced.
Source of deposit deserves its own line rather than a tick. Savings, a gift, equity from a sale, an inheritance and a director's loan all lead to different documentary evidence, and the case stops without it.
7. Mortgage preferences and priorities
This is the section that makes a suitability letter possible. What the client actually wants: rate certainty over flexibility, the lowest possible payment now, the ability to overpay, portability because a move is likely, speed because a chain is waiting. Recorded in the client's terms, these become the reasons a recommendation is suitable — and their absence is the single most common reason a suitability letter reads as generic.
8. The property
Address, tenure and — on a leasehold — the years remaining, property type and construction, year built, number of bedrooms and bathrooms, whether it is a new build, ex-local authority, above commercial premises, or has cladding. Each of these is a lender criteria question, and each is cheaper to answer now than after a valuation.
9. Existing protection
Provider, plan type, sum assured, term, premium, and who is covered. You need this to answer the protection question properly, and "none" is a valid answer that should be recorded as one rather than left blank — a blank cannot be distinguished later from a question nobody asked.
10. Vulnerability and Consumer Duty
Consumer Duty expects firms to consider characteristics of vulnerability — health, life events, resilience, capability — and to record the consideration, including when the conclusion is that there are none. A nil return that is written down is evidence; a nil return that was never asked is a gap.
11. Declarations and consent
The client's confirmation that the information is accurate, consent to the credit search and to processing their data, the date, and the signature. Undated declarations and a signature captured before the final version of the facts are the two most common audit findings.
The five gaps that send cases back
- Variable income merged into basic salary, so the lender's affordability calculation and yours never agree.
- A gap in three-year address history, which stalls the credit search.
- Deposit source recorded as an amount but not a source, so the anti-money-laundering evidence is missing.
- The initial rate end date left blank on a remortgage, making it impossible to show the advice was timed suitably.
- Client priorities not recorded in the client's own words, leaving the suitability letter with nothing specific to justify.
Paper, PDF, or captured as you go
A printed template is easy to start and hard to keep. It has to be transcribed into a system eventually, and transcription is where numbers change: a figure read off a payslip at the kitchen table becomes a slightly different figure typed up on Friday afternoon, and nothing in the file records which one the advice was based on.
The alternative is to capture the fact find from the evidence itself — the documents the client has already sent, and the conversation you have already had — so that each value can be traced back to where it came from. That is the approach Crestwell takes: it reads the paperwork, fills the fact find field by field, and shows the source behind each value for the adviser to accept or reject. The adviser still decides; the typing is what goes away.
See how the fact find is built from documents and meetings, with the evidence against every field. How it works.
A note on keeping it
Whatever shape your fact find takes, it has to be retrievable years later, in the state it was in when the advice was given. That means the version, the date, and the evidence behind it — not just the final PDF. Complaints and file reviews are decided on what the file can show, and a fact find that cannot be tied back to its sources is weaker than one that can, however neat it looks.