Case-file contents

A file review is only as good as the file. This page describes what a complete customer file looks like for each vertical, what the reviewer pulls onto their screen alongside the rubric, and how IAR files differ from full AR files.

The shape below is the FCA-expected minimum. Principal firms typically extend it with internal MI fields and broker-network identifiers. The product’s FileReview entity references the case by caseRef; the case itself is the AR’s source-of-truth record (in production, retrieved from the AR’s CRM or the principal’s central case store).

What every file contains, regardless of vertical

These items appear in every customer file the principal samples for review. The rubric does not call them out explicitly because they are pre-conditions for the rubric being scoreable at all.

Item	What it is	Why a reviewer needs it
Customer identity pack	Verified name, date of birth, address, NI/UTR where required, photo ID and proof of address copies.	Confirms the file is about a real, identifiable customer and establishes the start of the relationship for retention purposes.
First-contact record	Date, channel (phone, web, in-person), source of introduction.	Anchors the timeline and pins down which AR or IAR was responsible at first contact.
Consent record	Customer’s recorded consent to data processing, marketing, and (for credit) credit-search.	UK GDPR Article 6 / 7 and CONC 5.2A consent trail.
Adviser identity	Name, role, regulatory reference (where the AR’s individuals appear on the FS Register or under SMCR certification).	Lets the reviewer confirm the case was handled by someone competent to handle it.
Audit timestamps	When the file was opened, every material event, when it was closed.	Underpins SYSC 9 record-keeping and the principal’s ability to reconstruct the journey.
Communications log	Every customer-facing communication (email, letter, recorded call, SMS) with timestamps and direction.	The rubric’s “clear, fair and not misleading” tests are scored against these artefacts.
Outcome	Application submitted, lender / insurer / lender ID, completion date, declined reason if not.	Closes the loop on Consumer Duty consumer-support and price-and-value monitoring.

Mortgage broking (MCOB)

The full file for a residential mortgage case under Heritage Mortgage Network’s permission scope.

Fact-find

The structured customer-circumstances record. The mortgage fact-find is the input to suitability and affordability assessment, and a defective fact-find usually predicts a defective recommendation.

Required content:

• Income: employment status, gross / net pay, employer, length of service, second income, self-employment accounts (typically 2-3 years), benefits, pension. Source documents attached (payslips, accounts, SA302).
• Outgoings: committed expenditure broken down (housing, utilities, insurance, transport, credit, dependents, subscriptions). Bank statement evidence (typically 3 months) attached.
• Existing credit: outstanding balances, monthly payments, intent at completion (settle / continue).
• Property and deposit: source of deposit (savings, gift, equity), gifted-deposit declaration, property address, type, tenure, age, intended use.
• Objectives: term length, repayment vs interest-only, fixed vs variable preference, overpayment intent, future plans (children, house move, retirement).
• Personal circumstances: dependents, marital status, health considerations material to the application, retirement timing if approaching.
• Vulnerability indicators: any of FG21/1’s four drivers (health, life events, resilience, capability) flagged. A blank vulnerability section is itself a finding — it suggests the question wasn’t asked.

Suitability report

The narrative document the AR provides to the customer (and retains on file) explaining the recommendation. Required sections:

• The customer’s stated objectives, summarised back.
• The recommendation: lender, product code, rate, term, repayment type, fees.
• Why this product over alternatives (the suitability rationale — the test in MCOB 4.7A.6).
• Trade-offs disclosed (e.g. early-repayment charges, end-of-fixed reversion).
• Affordability evidence summary (with stress-test result per MCOB 11.6.5).
• Interest-only exit strategy if applicable (MCOB 11.6.18).
• Confirmation the recommendation has been explained verbally and the customer has had time to consider.

ESIS (European Standardised Information Sheet)

The pre-contract product disclosure (MCOB 5). Standardised template, must be issued before commitment and contain APRC, total amount payable, repayment schedule, and the binding offer’s headline terms.

Ancillary disclosures

• Initial Disclosure Document (IDD): status of the firm, products covered, fee structure, complaints route. Issued at outset (MCOB 4.4A).
• Fee agreement: signed broker fee schedule with the amount and timing.
• Procuration fee declaration: for any lender-paid commission, the disclosed amount or formula.
• Cooling-off notice: included in the offer pack (MCOB 5.6.16).
• Vulnerability adjustments: where vulnerability is identified, what was changed in the journey (extra time, plain-English summary, third-party-assistance acknowledgement).

Evidence pack

The supporting documents are attached to the file: ID, address, payslips / accounts, bank statements, credit report (if pulled), deposit-source evidence, gifted-deposit letter, valuation report (if at offer stage), source-of-funds for any large recent deposits.

What the reviewer pulls onto screen alongside the MCOB rubric

For each rubric item, the reviewer expects to see:

Rubric item	What the reviewer reads
MCOB 4.7A.2 (needs and circumstances)	Fact-find sections: objectives, income, outgoings, personal circumstances, vulnerability.
MCOB 4.7A.5 (recommendation suitable)	Suitability report rationale, lender criteria match, term and repayment match to objectives.
MCOB 4.7A.6 (rationale documented)	Suitability report’s “why this product” section.
MCOB 11.6.2 (income and expenditure verified)	Fact-find income / outgoings, source documents in the evidence pack.
MCOB 11.6.5 (stress test)	Affordability worksheet showing rate-rise stress applied.
MCOB 11.6.18 (interest-only exit strategy)	Suitability report’s exit-strategy section.
MCOB 5.5.1 (ESIS issued before commitment)	ESIS timestamp vs application submission timestamp.
MCOB 5.6.6 (ESIS content)	The ESIS itself.
MCOB 5.6.16 (cooling-off notice)	Offer pack.
MCOB 4.4A.1 (broker fee disclosed)	IDD and fee agreement.
MCOB 4.4A.4 (procuration fee structure declared)	Disclosure document.
FG21/1 (vulnerability)	Fact-find vulnerability section, adjustments record.
PRIN 2A (Consumer Duty outcome)	Suitability report’s Consumer Duty section, communications log.

General insurance (ICOBS)

The full file for a personal-lines or commercial GI case under Crown GI Collective’s permission scope.

Demands and needs statement

The structured record of what the customer is trying to insure and why (ICOBS 5.2). Lighter than a mortgage fact-find but still must capture: the asset / liability / life-event being covered, sums insured, geography, exclusions the customer is willing to accept, and any specific concerns (claims history, pre-existing conditions for travel / health, high-net-worth thresholds).

Personal recommendation (where given)

Where the AR moves beyond information-only and gives a personal recommendation, ICOBS 5.3 requires the recommendation to be explained. The file holds: the recommended policy, the alternatives considered, why the recommendation matches the demands and needs, and any limitations declared.

IPID (Insurance Product Information Document)

ICOBS 6.1.5 mandatory pre-sale standardised disclosure: cover, exclusions, premium, duration, cancellation. Issued before the customer commits.

Status, remuneration, and fair-value disclosures

• Status disclosure: the firm acts as a broker / intermediary, the panel of insurers, whether the recommendation is from a fair analysis or limited panel (ICOBS 6.4.1).
• Remuneration disclosure: commission structure, broker fees (ICOBS 6.4.4).
• Fair-value evidence: the principal’s fair-value assessment for the distribution arrangement (PROD 4.5), evidenced in the file or referenced to the firm-level documentation.

Claims-handling expectations

Set at sale (ICOBS 8.1.1): claims notification route, expected response timing, customer-side documentation that will be needed.

Evidence pack

Quote comparisons, panel details, customer disclosures (claims history, occupation, modifications for motor, prior conditions for travel / health), any underwriter-required certificates.

What the reviewer pulls onto screen alongside the ICOBS rubric

Rubric item	What the reviewer reads
ICOBS 5.2.2 / 5.2.3 (demands and needs)	The demands and needs statement and the customer disclosures.
ICOBS 5.3.1 (personal recommendation explained)	The personal recommendation document (where given).
ICOBS 6.1.5 (IPID)	The IPID, with timestamp before commitment.
ICOBS 6.4.1 / 6.4.4 (status / remuneration disclosure)	The cover-letter / disclosure pack.
PROD 4.5 / 4.5.6 (fair value)	Either the case’s fair-value summary or the firm-level fair-value assessment referenced in the file.
PRIN 2A.1 (consumer understanding)	Communications log, IPID, customer’s recorded acknowledgement.
FG21/1 (vulnerability at sale)	Demands and needs section, any adjustments record.
ICOBS 8.1.1 (claims expectations explained)	Sale-pack claims-route document.

Consumer credit (CONC)

The full file for a regulated consumer-credit broking case under Pinpoint Credit Network’s permission scope.

Pre-contract record

CONC 4.2 requires “adequate explanations” so the customer can decide whether the agreement is suited to their needs. The file holds: a transcript or summary of the explanation, the questions the AR asked to probe understanding, and the customer’s responses.

Creditworthiness assessment

CONC 5.2A requires the lender (and the broker, where it has the responsibility) to assess creditworthiness before granting credit. The file holds: the income / expenditure record, the credit-search result (with consent), the affordability calculation, and the decision rationale. CONC 5.2A.10 requires the sources of information used for the assessment to be recorded; CONC 5.2A.20 requires the assessment to be customer-specific (no rule-of-thumb).

Pre-contract Credit Information document (PCCI)

CONC 4.2.15 standardised pre-contract disclosure: total amount of credit, APR, total payable, repayment schedule, default and late-payment consequences. Issued before agreement.

Status, fee, and commission disclosures

• Status: broker, panel of lenders, whether independent or limited (CONC 4.4).
• Broker fee: amount, timing, customer’s signed consent (CONC 4.4.4).
• Commission: amount or formula, disclosed adequately (CONC 4.5.3) — the FCA’s 2024 motor-finance interventions raised the bar for “adequate”.

Adverse-consequences explanation

CONC 4.2.8 requires the AR to have explained the adverse consequences of payment difficulties (default fees, credit-file damage, legal action). The file holds the explanation and customer acknowledgement.

Evidence pack

Income evidence, bank-statement excerpts where pulled, credit-search consent and result, dependent / household disclosure, affordability worksheet, signed agreement.

What the reviewer pulls onto screen alongside the CONC rubric

Rubric item	What the reviewer reads
CONC 4.2.5 (adequate explanations)	Pre-contract record, communications log.
CONC 4.2.7 (understanding probed)	Pre-contract record’s question-and-answer section.
CONC 4.2.8 (adverse consequences)	Pre-contract record’s adverse-consequences section, customer acknowledgement.
CONC 5.2A.4 (creditworthiness assessment)	Affordability worksheet, credit-search result.
CONC 5.2A.10 (sources recorded)	Worksheet’s sources column, evidence pack.
CONC 5.2A.20 (customer-specific)	Customer-level inputs, not template defaults.
CONC 4.2.15 (PCCI)	The PCCI document, timestamp before agreement.
CONC 4.4.2 (APR and total payable)	The PCCI and the agreement.
CONC 4.4.4 / 4.5.3 (fees and commission)	Disclosure pack and signed consent.
FG21/1 (vulnerability)	Pre-contract record’s vulnerability section, adjustments record.
PRIN 2A.4 (consumer support)	Post-sale communications, complaints / arrears handling where applicable.

IAR files (introducer scope)

An IAR file is materially different. The IAR has not advised, has not arranged, and has not dealt; the file should reflect that and would be a SUP 15-notifiable problem if it didn’t.

What an IAR file contains

Item	What it is
Introduction record	Date, AR/IAR identity, customer identity, product context (which of the principal’s products the customer was directed to), channel.
Status disclosure record	Customer’s recorded acknowledgement that they were dealing with an introducer, not the principal, and that the principal will pick the case up.
Information collected	Whatever the IAR collected to qualify the introduction (e.g. name, contact, basic financial position). The IAR should not have collected the depth required for advice.
Communication artefacts	Any promotional material the IAR showed the customer, the principal’s product literature used, the script (where one was followed).
Hand-off record	Timestamp of hand-off to the principal, customer-facing acknowledgement, any vulnerability flag passed forward.
Commission / referral disclosure	Amount or formula, customer’s recorded acknowledgement before the introduction.
Consent	Customer’s consent to be passed to the principal and have their data shared.

What an IAR file should not contain

The presence of any of these in an IAR file is a red flag:

• A suitability report or recommendation document.
• An affordability worksheet completed by the IAR.
• An ESIS, IPID, or PCCI issued by the IAR (these come from the principal post-introduction).
• Application forms completed by the IAR for submission to a lender / insurer.
• Comparisons of the principal’s products against external providers (this is advice).

The IAR rubric (see File-review rubrics) is built around exactly this distinction: introduction quality, status and remuneration disclosure, scope adherence, and hand-off.

What the reviewer pulls onto screen alongside the IAR rubric

Rubric item	What the reviewer reads
SUP 12.2.2 (within scope)	The principal’s appointment contract terms vs the introduction record.
SUP 12.5.5 (introducer status)	The status disclosure acknowledgement.
PRIN 7 (clear, fair, not misleading)	Communication artefacts and the script.
SUP 12.5.6 (status disclosure)	The disclosure pack.
DISP 1.2 (complaints route to principal)	Customer-facing materials.
CONC 4.5 / ICOBS 4 / MCOB 4.4A (commission / referral fee disclosed)	Disclosure record and acknowledgement.
SUP 12.2.10 (no advice given)	Communications log, file content — looking for the absence of suitability commentary.
SUP 12.2.11 (no arranging)	File content — looking for the absence of application completion.
SUP 12.2.12 (only approved material used)	Communication artefacts vs the principal’s approved-material list.
PRIN 2A (information accurate at hand-off)	Hand-off record vs information collected.
FG21/1 (vulnerability flagged)	Hand-off record’s vulnerability section.
SYSC 9 (introduction recorded)	The introduction-record fields, timestamps, consent.

Sampling: which files end up in the reviewer’s queue

Not every file is reviewed. The principal’s file-review programme samples cases against a sampling rule (the reviewer does not pick — that would defeat the point). The product’s FileReview records the caseRef, but the sampling logic that selected the case lives in the firm’s review-programme documentation. The standard sampling rules a principal uses, encoded for the v2 of this product:

Rule	What it does	Why
Random	A baseline percentage of the AR’s monthly cases pulled at random.	Establishes a population view, prevents gaming.
Risk-weighted	Higher proportion sampled from ARs in the elevated, high, and critical risk bands.	Where the risk score signals concern, the sampling rate reflects it.
Targeted	All cases of a specific type (e.g. interest-only mortgages, sub-prime credit, vulnerable-customer-flagged cases).	Targets the highest-impact failure modes.
Complaints-driven	The case underlying any upheld complaint pulled automatically.	Closes the feedback loop from complaint to root cause.
Anomaly-driven	Cases on which the MI return’s anomaly score implicates a pattern (e.g. unusually high commission, very short journey time).	Catches systemic patterns the random and risk-weighted samples might miss.

For an IAR network, “random” and “anomaly-driven” do most of the work — there are fewer high-risk-band IARs because the rubric scope is narrower and the volume of files per IAR is typically much higher than for a full AR.

File retention

Cases retained for the SYSC 9 floor (six years from completion) with sector overlays in MCOB / ICOBS / CONC. The product applies a seven-year default to leave a buffer above the longest commonly applicable floor. The FileReview itself is retained against the same window. See Retention.

See also

• File-review rubrics — the scoring criteria the reviewer applies to each item above.
• File review workflow — how the review surface in the product organises the work.
• Data shapes — the FileReview and FileReviewFinding types.
• SUP 12 (the AR rulebook) — the source of the AR / IAR scope distinction.