Why We File Check?
File checking is the main evidence the Network holds that advice across our Appointed Representatives is suitable and that customers are getting good outcomes. It is also the first place the FCA looks when it tests how a principal firm oversees its ARs.
Most files we review are sound. The issues we do find are rarely about the advice being wrong they are about the file not showing why the advice was right. A recommendation that cannot be explained from the file is, in regulatory terms, a recommendation that cannot be defended.
Four themes are coming up most often in recent checks. None of them require more work on a case; they require the work that is already being done to be written down at the time.
What a clean file looks like
f you want a single test before you submit, ask whether someone with no knowledge of the case could read the file and understand what the client needed, what you recommended and why. A clean file contains:
- A fact find that sets out the client’s circumstances, objectives and priorities not just the data points needed to source a product.
- A recommendation rationale written in the client’s own circumstances, including why the alternatives were not chosen.
- Evidence of income, expenditure and identity, collected before submission.
- A recorded protection conversation and its outcome whatever that outcome was.
- Any vulnerability identified, the support offered, and how it affected the advice.
- Disclosure documents issued at the right point in the process, signed or evidence it has been sent via email where required.
- A complete case on OMS at the point of submission, not after.
- Remedials from previous checks cleared, with evidence, inside the timescale given.
File checks are not a scoring exercise. They are how we evidence competence for each adviser and how we identify problems early, while they are still easy to fix. Where the same findings keep recurring on an adviser’s files, the position moves from feedback to formal remedial action, so the quickest route through the process is to close out each query properly the first time it is raised.
The Compliance team is here to support you, not to catch you out. If a finding has been raised on one of your files and you are not clear why, or you want to talk through what we would expect to see on a particular type of case, contact us and we will go through it with you in detail on a case-by-case basis.
For any questions or queries, contact the Compliance Team. Call: 01708 676110 or Email: compliance@connectmortgages.co.uk
Best regards,
Shahrukh Malik
Compliance Director