When to write a file note, what it should contain, and what the rules and the Ombudsman expect to see on a mortgage or protection file.
Written by
Charlotte BrownRole
Mortgage Industry Writer
A file review asks one question: could someone who was not on the call see what you knew, what you recommended and why? Network file checks, complaints and regulator requests all start from the file, and the file notes are the part of it that only you can write.
The rules say what the record must show. They don't say what a file note looks like. This guide covers when to write one and what goes in it, then shows what Cleera records for you and what you still write yourself. It leaves the wider question of what a whole case record should hold to the posts that already cover it. Each rule and source below was checked against its live page on 5 October 2026.
| Rule | What it requires | Fixed retention period |
|---|---|---|
| MCOB 4.7A.25R | For an advised mortgage sale: a record of the customer information, including their needs and circumstances; a record explaining why the advice meets the suitability requirement; the customer's positive choice if fees are added to the loan; and the explanation you gave if you did not recommend the cheapest suitable option | A minimum of three years from the date of the advice or explanation |
| ICOBS 5.2.2R and 5.3.1R | For protection advice: specify the customer's demands and needs before the contract is concluded, and take reasonable care that your advice is suitable | Neither rule states one |
| SYSC 9.1.1R | Keep orderly records of your business, enough for the FCA to monitor your compliance and to see that you met your obligations to clients | None for non-MiFID business. SYSC 9.1.5G says records should be retained for as long as is relevant for the purposes for which they are made |
| PRIN 2A.9 | Monitor the outcomes your retail customers receive and act on what you find. PRIN 2A.9.15G leaves it to the firm to decide what Consumer Duty records to keep | None prescribed |
| DISP 1.9.1R | Keep a record of each complaint and the steps taken to resolve it | Three years for most complaints, from the date received |
| UK GDPR Article 5(1)(e) | Keep personal data no longer than is necessary for the purpose | None. The ICO says it is for the firm to decide and justify |
SYSC 9.1.1R covers firms other than common platform (MiFID) firms. If you are unsure how it applies to your permissions, ask your network or compliance consultant. The FCA compliance and CRM guide covers what your system needs to support under MCOB and SYSC 9.
The only fixed minimum MCOB sets for the advice record is three years. Other rules, such as anti-money-laundering record keeping where it applies to your firm, can require some records to be kept longer. A complaint can still reach the Financial Ombudsman Service up to six years after the event, or three years after the customer became aware of the problem if that is later, provided it is referred within six months of your final response (DISP 2.8.2R). The Ombudsman can accept a late complaint in exceptional circumstances or where the firm consents.
So three years is a floor, not a sensible retention policy. Set a longer period in a written retention schedule and be able to explain it, because UK GDPR also expects you not to keep data longer than you need.
No FCA rule prescribes a format for file notes, and PRIN 2A.9.15G leaves it to each firm to decide what Consumer Duty records to keep. The best guide to what is asked for in practice is the Financial Ombudsman Service's own list. For a mis-sold mortgage complaint it asks for, among other things, the fact find, application form, suitability or recommendation letter, "contact and application notes from the time of the sale", evidence of affordability checks, a call recording of the application meeting, and details of other products considered and why this one was the most appropriate.
A usable file note records:
Write it at the time of the contact, because notes "from the time of the sale" are what the Ombudsman asks for. If a note turns out to be wrong, add a dated follow-up note rather than altering the original.
This is an invented example to show the difference.
| Weak | Usable |
|---|---|
| Called client re mortgage. Happy to proceed. | 5 Oct, 14:10, phone, 12 minutes, both applicants. Sam is self-employed, so income for the application is Alex's salary plus Sam's 2025 SA302. Both prefer a five-year fix for payment certainty and understand early repayment charges apply for the full five years. Asked about overpayments: explained the lender's annual allowance. Agreed: I send the suitability letter by Friday, they upload Alex's September payslip by 12 Oct. |
A note belongs on the file whenever a contact changes what you know, what you advised or what the client decided. In a typical mortgage and protection case that means:
Each of these maps back to the record MCOB 4.7A.25R or ICOBS 5.2.2R asks for. The onboarding process guide covers the front of the file, and the post on what to do when a client says no to protection covers that conversation in detail.
If a client has needs that change how you advise, record what you need to meet them and no more. FCA guidance FG21/1 reminds firms that recorded information should be "adequate, relevant and limited to what is necessary", and says it should be enough "to understand their needs and translate that into action, but not more than that which is necessary". It also says firms "may choose to record the interventions or support requested by a customer rather than the vulnerability itself", but warns that if the vulnerability could be inferred from that record, it may be special category data and has to be treated as such. A short note of the adjustment you made and why can be enough. The vulnerable customer policy guide covers the policy side.
For an intermediary, the Duty's outcomes (products and services, price and value, consumer understanding, consumer support) show up in file notes as what you explained and how you checked the client understood, what you told them about fees, and what you did when their circumstances changed.
The FCA's outcomes monitoring good practice, published on 27 July 2026, describes proportionate day-to-day checks of "calls, files, complaints or customer feedback" for smaller firms. Those checks only work if the notes on the file say something. For firm-level monitoring and board reporting, see the Consumer Duty outcomes monitoring guide, and for the wider record-keeping picture, the Consumer Duty case records guide.
Cleera drafts, flags and organises. It does not decide, and it does not make a file compliant by itself: you decide what is recorded and you approve it. This is what the system records and what is still yours to write.
| On the file | What Cleera does | What you still do |
|---|---|---|
| Case notes | Saves each note with its author and the time. There is no way to edit a saved note in Cleera | Write the note. Add a dated follow-up to correct one |
| Call and meeting notes | On Solo Pro and above, you can record a call or send Cleera Notetaker to a meeting, and Cleera drafts a file note. It is saved to the case only after you review it, edit it if needed, and approve it. Discarding the draft deletes the transcript and audio | Tell the client, confirm consent before recording starts (Cleera records the time you confirm it, and the tick is your confirmation, not the client's), and check names, numbers and dates before approving |
| Documents | Keeps a checklist per case. Uploads wait for your approval before the request is marked verified, and approvals and rejections are logged with who and when. Identity documents are marked verified when the ID check returns Approved | Review each document and give a reason when you reject one |
| Client messages | Stores messages sent through the portal on the case | Record the key points of important emails in a case note, because emails are not captured |
| Suitability letter | On Solo Pro and above, drafts six sections for you to edit. Once you finalise it, it is locked, and you can send it for e-signature | Check each section against the fact find before you finalise |
| Status and stage changes | Logs each status change and each stage move with who and when. Declining a case requires you to say who ended it: client, provider, adviser withdrawn or other | Add a case note with the reason, because there is no free-text decline reason |
| Audit log | Records more than 100 kinds of event, including status and stage changes, document approvals, notes and exports, with the user and time where a person acted. The firm Owner can view it and filter by case | Use the case export for a file review, because the log cannot be exported and covers the whole firm |
| Case export | Produces one ZIP with a summary PDF (case details, notes with their author, the suitability letter and its status, forms, documents, tasks and e-signatures) and the case files | Add what the export leaves out: audit events, portal messages and call transcripts |
The client portal holds the messages and document checklist, the digital fact-find feeds the case record, and Features lists the rest. For the safe-use side of AI drafting, see AI for mortgage brokers.
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The only fixed minimum MCOB sets for the advice record is three years from the date of the advice (MCOB 4.7A.25R). That is a floor, not a retention policy, and other rules can require some records to be kept longer. A complaint can reach the Financial Ombudsman Service up to six years after the event, or three years after the customer became aware of the problem if that is later (DISP 2.8.2R). UK GDPR sets no period, so choose one, write it into a retention schedule and be ready to explain it.
No FCA rule prescribes file notes or a format, and PRIN 2A.9.15G leaves it to each firm to decide what Consumer Duty records to keep. In practice, any contact that changes what you know, what you advised or what the client decided belongs on the file. The Financial Ombudsman Service asks for contact and application notes from the time of the sale when it investigates a mortgage complaint.
There is no prescribed template or retention period. PRIN 2A.9.15G says firms will need to decide, in line with the high-level record-keeping rules in SYSC 3 and SYSC 9, what records they need to keep for their Consumer Duty obligations. For a single case, that means the file shows the client's needs, why the recommendation fits them, what they were told about fees, and how you checked they understood.
Record what you need to meet their needs, not more. FCA guidance FG21/1 says recorded information should be adequate, relevant and limited to what is necessary, and that firms may record the support a customer asked for rather than the vulnerability itself, though if the vulnerability could be inferred from that record it may still be special category data. A short note of the adjustment you made and why can be enough.
It can draft them, but you remain responsible for what goes on the file. In Cleera, a recorded call or meeting produces a drafted note that is saved to the case only after you review it, edit it if needed, and approve it, and discarding the draft deletes the transcript and audio. Speech-to-text can mishear, so check names, numbers and dates before you approve.
It records who did what and when for case status and stage changes, document approvals, notes, forms, e-signature requests and exports, more than 100 kinds of event in all, and the firm Owner can view and filter it by case. It cannot be exported, and it does not hold your messages or call transcripts. For a file review, use the case export, which bundles a summary PDF and the case files, and add anything else the reviewer needs.
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