File-review rubrics

A file-review rubric is the structured checklist a compliance reviewer scores against when sampling an AR’s customer files. Each rubric maps to one regulatory permission scope: MCOB for residential mortgage broking, ICOBS for general insurance broking, CONC for consumer credit broking. A fourth, vertical-agnostic IAR rubric is used whenever the AR under review is an Introducer Appointed Representative.

The demo ships the canonical set in lib/rubrics.ts. In production these seed the database; principal-admin can override per-tenant in a later release.

AR vs IAR: rubric branching

The right rubric is the one whose scope matches the AR’s appointment. An IAR may not give regulated advice, may not arrange, and may not deal. Reviewing an IAR file against MCOB suitability or ICOBS demands-and-needs would test obligations the IAR is not subject to and would miss the obligations the IAR is subject to (status disclosure, scope adherence, hand-off accuracy).

The product picks the rubric in getRubric(code, arType):

export function getRubric(code: RubricCode, arType: ArType = "AR"): RubricItem[] {
  if (arType === "IAR") return IAR_ITEMS;
  return RUBRICS[code];
}

The file-review surface reads ar.type from the AR record and renders the IAR rubric without further config. Reviewers see an “introducer scope” badge in the header and a one-line explanation that suitability and affordability items have been filtered out.

This means a single principal firm can supervise a mixed network — full ARs reviewed against MCOB, IARs reviewed against IAR — or an entirely IAR network (e.g. an estate-agent referral network introducing to a mortgage principal) reviewed entirely against the IAR rubric.

See also: Case-file contents for what the reviewer is looking at when they score each item.

Format

lib/rubrics.ts

export interface RubricItem {
  /** Handbook reference, e.g. "MCOB 4.7A.2R". */
  code: string;
  /** Plain-language descriptor. */
  label: string;
  /** Section grouping (e.g. "Suitability", "Disclosure"). */
  section: string;
}

export type RubricCode = "MCOB" | "ICOBS" | "CONC";

export const RUBRICS: Record<RubricCode, RubricItem[]>;

A FileReviewFinding references an item by itemCode, denormalises the itemLabel for audit immutability, and records the reviewer’s outcome (pass, advisory, fail, n/a), evidence, and remediation. See Data shapes.

Scoring

score (0-100) is the mean of non-n/a outcomes:

Outcome	Numeric
pass	1.0
advisory	0.7
fail	0.0
n/a	excluded

score = 100 * mean(applicable outcomes).

Helpers

export function getRubric(code: RubricCode): RubricItem[];
export function getRubricSections(code: RubricCode): string[];

getRubricSections returns sections in their first-seen order, which is the order the workspace UI groups items.

MCOB (mortgage broking)

Used by Heritage Mortgage Network in the demo.

Suitability (MCOB 4.7A)

Code	Label
MCOB 4.7A.2	Customer’s needs and circumstances were assessed
MCOB 4.7A.5	Recommendation is suitable for the customer
MCOB 4.7A.6	Suitability rationale is documented

Affordability (MCOB 11.6)

Code	Label
MCOB 11.6.2	Income and committed expenditure verified
MCOB 11.6.5	Stress test applied for interest rate increases
MCOB 11.6.18	Interest-only repayment strategy evidenced

Disclosure (MCOB 5)

Code	Label
MCOB 5.5.1	ESIS issued before customer commitment
MCOB 5.6.6	ESIS contains required pre-contract information
MCOB 5.6.16	Cooling-off period notice included

Fees

Code	Label
MCOB 4.4A.1	Broker fee disclosed before customer commitment
MCOB 4.4A.4	Procuration fee structure declared

Vulnerable customer

Code	Label
FG21/1	Vulnerability indicators considered and recorded

Consumer Duty

Code	Label
PRIN 2A	Consumer Duty outcome assessment captured

ICOBS (general insurance broking)

Used by Crown GI Collective in the demo.

Demands and needs (ICOBS 5.2)

Code	Label
ICOBS 5.2.2	Customer demands and needs identified
ICOBS 5.2.3	Statement of demands and needs documented

Suitability (ICOBS 5.3)

Code	Label
ICOBS 5.3.1	Personal recommendation explained

Disclosure (ICOBS 6)

Code	Label
ICOBS 6.1.5	Insurance Product Information Document provided
ICOBS 6.4.1	Status disclosure (broker vs intermediary)
ICOBS 6.4.4	Remuneration disclosure (commission)

Fair value (PROD 4)

Code	Label
PROD 4.5	Fair value assessment for the distribution arrangement
PROD 4.5.6	Premium-to-cover ratio appropriate for target market

Consumer Duty

Code	Label
PRIN 2A.1	Consumer understanding outcome documented

Vulnerable customer

Code	Label
FG21/1	Vulnerability indicators captured during sale

Claims

Code	Label
ICOBS 8.1.1	Claims handling expectations explained at sale

CONC (consumer credit broking)

Used by Pinpoint Credit Network in the demo.

Pre-contract (CONC 4)

Code	Label
CONC 4.2.5	Adequate explanations given to enable informed decision
CONC 4.2.7	Customer’s understanding probed before agreement
CONC 4.2.8	Adverse consequences of payment difficulties explained

Creditworthiness (CONC 5.2A)

Code	Label
CONC 5.2A.4	Creditworthiness assessment carried out before granting credit
CONC 5.2A.10	Sources of information for the assessment recorded
CONC 5.2A.20	Customer-specific affordability assessment performed

Disclosure (CONC 4)

Code	Label
CONC 4.2.15	Pre-contract credit information document provided
CONC 4.4.2	Total amount payable and APR disclosed

Fees

Code	Label
CONC 4.4.4	Broker fee disclosed and consented to
CONC 4.5.3	Commission disclosure adequate

Vulnerable customer

Code	Label
FG21/1	Vulnerability indicators captured in the customer file

Consumer Duty

Code	Label
PRIN 2A.4	Consumer support outcome recorded

IAR (introducer scope, vertical-agnostic)

Used whenever the AR under review has type: "IAR", regardless of whether the principal firm holds MCOB, ICOBS, or CONC permissions. Sources: SUP 12.2 (IAR scope), SUP 12.5 (written-contract scope), PRIN 7 (clear, fair and not misleading), PRIN 2A (Consumer Duty at point of introduction), FG21/1 (vulnerability identification at first contact).

Introduction quality

Code	Label
SUP 12.2.2	Introduction was within the scope of the IAR appointment
SUP 12.5.5	Customer informed they are dealing with an introducer, not the principal
PRIN 7	Information about the principal’s product was clear, fair, and not misleading

Disclosure

Code	Label
SUP 12.5.6	Status disclosure (regulated via the principal) provided to customer
DISP 1.2	Complaints route to the principal explained
CONC 4.5 / ICOBS 4 / MCOB 4.4A	Any commission or referral fee disclosed before introduction

Scope adherence

The failure mode for IARs. An IAR who advises, recommends, or arranges has stepped outside the scope of its appointment, which is itself a SUP 15-notifiable issue.

Code	Label
SUP 12.2.10	No regulated advice given (no recommendation, no comparison, no opinion on suitability)
SUP 12.2.11	No arranging activity carried out (no application completion, no submission)
SUP 12.2.12	Only the principal’s approved promotional material was used

Hand-off

Code	Label
PRIN 2A	Customer information collected was accurate and complete at hand-off
FG21/1	Vulnerability indicators flagged to the principal at hand-off
SYSC 9	Introduction recorded with timestamp, customer consent, and product context

Per-tenant overrides (production, planned)

In production, principal-admin can:

1. Add tenant-specific items (e.g. an internal anti-bribery checklist alongside the regulatory items).
2. Mark canonical items as inapplicable for a specific permission profile (e.g. an IAR permission scope that does not advise).
3. Edit label text. The code is immutable; reviewers always reference the same handbook citation.

Overrides are versioned. A file review references the rubric version it was scored against, so a change to the rubric does not retroactively alter prior reviews. The annual-review packet shows the rubric version at the time of each review.