What Does a Good Mortgage File Look Like? A Compliance Reviewer’s Checklist

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Every mortgage broker has asked themselves the same question at some point…

“If my files were reviewed by the FCA tomorrow, would they stand up to scrutiny?”

Most advisers know when they’ve produced a good piece of advice. But compliance isn’t just about recommending the right mortgage.

A well-presented mortgage file should clearly demonstrate how you reached your recommendation, why it was suitable for the client and how you’ve achieved a good customer outcome. At H3 Consultancy, we review mortgage files every day.

While every firm has its own processes, the same themes appear time and time again.

In this guide we’ll explain:

  • What makes a high-quality mortgage file.
  • What compliance reviewers are looking for.
  • The most common issues we identify.
  • Simple ways to improve file quality.
  • How regular file reviews support Training & Competency and Consumer Duty.

1. Does the Fact Find Tell the Customer’s Story?

Everything starts with the fact find. A good file should paint a complete picture of the customer’s circumstances.

Ask yourself:

  • Have I fully documented income and expenditure?
  • Have I explored the customer’s objectives?
  • Have I recorded future plans?
  • Have I discussed attitude to risk where relevant?
  • Have I identified any vulnerabilities?
  • Have I recorded any limitations or assumptions?

A recommendation is only as good as the information it is based upon. Incomplete fact finds remain one of the biggest causes of unsuitable advice.

2. Is the Customer’s Objective Clear?

One of the simplest questions a compliance reviewer asks is:

“What is this customer actually trying to achieve?”

If the objective isn’t clearly documented, it’s difficult to demonstrate why the recommendation is suitable.

Your file should explain:

  • Why the customer is remortgaging or purchasing.
  • Their priorities.
  • Their concerns.
  • Any future plans.
  • Any preferences discussed.

If another adviser picked up the file tomorrow, would they understand exactly what the customer wanted?

3. Can You Justify Your Recommendation?

It’s not enough to recommend a lender. You should be able to explain why.

Good files demonstrate:

  • Products considered.
  • Research undertaken.
  • Why alternatives weren’t suitable.
  • Why the recommended product best met the customer’s needs.

The recommendation should follow naturally from the evidence contained within the file.

4. Is Affordability Properly Evidenced?

Affordability remains a key area of focus.

Good files demonstrate:

  • Income has been verified.
  • Expenditure has been considered.
  • Lending limits have been assessed.
  • Any assumptions are documented.
  • Lender criteria have been checked.

Reviewers should never have to guess how affordability was assessed.

5. Are Your File Notes Strong Enough?

One of the biggest differences between average files and excellent files is the quality of the notes.

Good notes explain:

  • Discussions held.
  • Advice given.
  • Customer decisions.
  • Alternative options discussed.
  • Questions raised by the client.
  • Any risks explained.

If it isn’t recorded, it’s very difficult to demonstrate it happened.

6. Have You Considered Consumer Duty?

Consumer Duty should be visible throughout the file—not simply mentioned in a policy document.

Ask yourself:

  • Have I acted in the customer’s best interests?
  • Have I communicated clearly?
  • Has the customer understood my recommendation?
  • Have I identified any foreseeable harm?
  • Have I tailored my approach where appropriate?

A reviewer should be able to see evidence of good customer outcomes.

7. Have You Identified Vulnerable Customers?

Vulnerability isn’t always obvious. A good file demonstrates that you’ve considered whether the customer may need additional support.

Where relevant, record:

  • Additional communication needs.
  • Health considerations.
  • Financial resilience.
  • Life events.
  • Reasonable adjustments provided.

Even where no vulnerability exists, many firms now record that consideration has taken place.

8. Does the File Make Sense From Start to Finish?

One of the simplest tests is this…

Could another adviser pick up your file six months later and understand:

  • What the customer wanted?
  • Why you made your recommendation?
  • How affordability was assessed?
  • Why alternatives weren’t selected?
  • What discussions took place?

If the answer is yes, you’ve probably produced a strong file.

Common Issues We See

Although every adviser is different, some themes appear repeatedly during compliance reviews.

These include:

❌ Incomplete fact finds.

❌ Weak suitability letters.

❌ Limited explanation of research.

❌ Missing affordability evidence.

❌ Poor quality file notes.

❌ Customer objectives that aren’t clearly documented.

❌ Little evidence of Consumer Duty considerations.

The good news is that these issues are usually easy to address once identified.

A Simple Mortgage File Checklist

Before submitting any application, ask yourself:

✔ Would another adviser understand this file?

✔ Is the customer’s objective obvious?

✔ Can I justify my recommendation?

✔ Have I evidenced affordability?

✔ Have I recorded key conversations?

✔ Have I considered vulnerability?

✔ Can I demonstrate good customer outcomes?

✔ If the FCA reviewed this tomorrow, would I be comfortable?

If you can confidently answer “yes” to each question, you’re giving yourself the best possible chance of producing a high-quality compliant file.

Why Regular File Reviews Matter

Even experienced advisers develop habits over time.

Regular file reviews help identify:

  • Recurring documentation issues.
  • Training needs.
  • Areas of good practice.
  • Opportunities to improve consistency.
  • Themes that may affect Consumer Duty outcomes.

Perhaps most importantly, they provide evidence that advice quality is being actively monitored rather than assumed. For firms operating a Training & Competency scheme, file reviews are one of the strongest ways to evidence adviser competence and support ongoing professional development.

Final Thoughts

A good mortgage file doesn’t just demonstrate that you’ve recommended the right product—it demonstrates how and why you reached that recommendation.

When files are well documented, they protect your clients, support your business and make regulatory reviews significantly less stressful.

At H3 Consultancy, we carry out independent mortgage file reviews for directly authorised firms, networks and firms developing advisers towards Competent Adviser Status. Every file is assessed against a structured compliance framework, graded for quality and accompanied by practical feedback designed to improve advice standards rather than simply identify faults.

Whether you’re preparing an adviser for CAS, strengthening your Training & Competency programme or simply looking for reassurance that your files meet regulatory expectations, independent file reviews provide objective insight, meaningful coaching opportunities and confidence that your advice stands up to scrutiny.ing one of the most important decisions in the adviser journey—awarding Competent Adviser Status.