Mortgage Magic Blog

  Most brokers do not fail a file review because the file is empty. They struggle because the reviewer asks a question the file was never built to answer. What did you know when you made the recommendation? What did the client tell you then, rather than now? What changed between the recommendation and completion, and who agreed to it? A tidy file can still leave those questions open. An audit trail closes them. There is no rule called “the audit trail” The FCA does not use that phrase for mortgage advice, but its rules describe the thing itself. Firms must keep customer information obtained for assessing suitability, along with records of why the advice is suitable, the customer’s positive choice to add fees to the loan, and the explanation where a cheaper product was not recommended. Each is kept three years from when the advice or choice was made. How those records are kept matters as much as whether they exist. The FCA’s guidance in MCOB 2.8 says a record is readily accessible i...

The contract renewal date rarely lines up with a quiet month. A firm decides its CRM is costing more than it gives back, the notice period starts, and the switch lands in the middle of a live pipeline. The client records will come across, because that is the part every vendor has a tool for. The risk sits in the things a data export does not carry, and in the obligations that stay behind with the old system after you have stopped logging in. What does not break Your obligations do not move with your software. The FCA requires mortgage firms to keep customer information obtained for assessing suitability for three years from when advice was given. Those records must also be readily accessible, meaning available for inspection within two business days of the request being received. That applies on the day you switch, the day after, and for every case you advised on in the old system. Your ownership of the data does not change either. Your old CRM provider processes client data on your be...

  It is 3pm on a Friday. You have three cases you meant to submit this week. One is waiting on a payslip the client promised on Tuesday. One has a fact-find you typed up from meeting notes, and you have just noticed there is no start date for the client's current job. The third is fine, but you cannot remember whether you sent the ID request, so you open your inbox to find out. This scenario is an illustration, not a customer case. None of that is advice. All of it is work. Where the hours actually go Hard independent data on this is thin, and that is worth saying plainly. The most quoted UK figures come from technology vendors. In a Finova survey, 58% of brokers said they spent 5-10 hours per week on admin and 41% said 11 to 20 hours. Among the most time-consuming tasks, 47% named digitising physical documents. Finova sells mortgage software, and this research dates from October 2024. Treat it as an indication, not a benchmark. Nivo, another vendor, reported that only half of subm...

  Every AI demo works. The vendor chooses the case, the inputs are clean, and the output lands exactly where it should. Nobody books a demo to show you the case where the tool got it wrong. That is the problem with judging AI on a demo. In a regulated advice business, the important question is not how the tool performs on a good day. It is what happens on a bad one: who notices, who decides what to do, and where that decision is written down. ISO 42001 is the closest thing the market has to an answer. It is also widely misunderstood, sometimes by the firms that hold it. What ISO 42001 actually is ISO/IEC 42001:2023 is the international standard that specifies requirements for establishing, implementing, maintaining, and continually improving an artificial intelligence management system, usually shortened to AIMS. Published in December 2023, it sits in the same family as ISO 27001 and ISO 9001. ISO lists its methodology as a management system standard following the Plan-Do-Check-Act...

  Nobody publishes a reliable figure for how long UK brokers spend retyping client details between systems, so any number you see quoted without a source should be treated with suspicion. What can be shown is where the cost sits. It is not mainly in the minutes. It is in the errors that enter when data is retyped, the records that stop agreeing with each other, and the cases that stall because something was wrong the first time. The part you can count yourself Time is the easiest cost to measure and the least interesting one, so it is worth doing quickly. Pick five recent cases and note every system where the client's details were typed in. Count the systems. Then time one case from first entry to the last. To see how it adds up, assume for illustration that retyping costs ten minutes per case, and that you complete 40 cases a month. That is 400 minutes, just under seven hours a month. The ten minutes is an assumption, not a measured figure, and your own number may be higher or low...

  A spreadsheet costs nothing to open, which is exactly why its real cost rarely gets counted. For a network, that cost shows up in four places: rules that change while the sheet stays the same, errors nobody can see, evidence that cannot be produced when the regulator asks, and hours that never appear on any invoice. None of it is dramatic on a given day. All of it surfaces at once when someone outside the firm asks to see the record. What a principal firm actually has to keep track of SM&CR sits with the principal firm, not with its appointed representatives, which means the network carries the accountability for what its ARs do under the agreement. In practice, that gives a network a set of recurring, date driven obligations. A named Senior Manager needs to be accountable for oversight of the ARs. Staff of the network itself who hold certification roles must be assessed as fit and proper and certified every year. The FCA must be notified at least 30 days before a new AR is a...