Mortgage Fact Find: What to Ask and Why

A fact find is where most of the advice is decided, because everything downstream rests on what it contains. When the FCA reviewed mortgage advice in 2015, it could not tell whether the recommendation was suitable in 38% of the mystery shops and files it looked at, and the reason it gave was that many firms had not taken reasonable steps to obtain enough relevant information.

This guide covers what the rules ask the fact find to establish, what to cover, how to probe without turning it into an interrogation, and how to keep it current between cases. For the document that follows it, see the guide to the mortgage suitability report. For a walkthrough of the whole onboarding process, see how to build a mortgage client onboarding process.

What the rules ask for

MCOB 4.7A does not set out a fact find or a list of questions. It sets the outcome the information has to support.

Rule	What it says	What it means for the fact find
MCOB 4.7A.4G(1)	A firm should take reasonable steps to obtain from the customer all information likely to be relevant	The test is whether you asked enough, not whether the form was full
MCOB 4.7A.5R(2)	Base the assessment on the facts the customer disclosed and other relevant facts you are, or should reasonably be, aware of	A fact you could reasonably have found out counts, even if the client did not mention it
MCOB 4.7A.6R	Consider the relevant factors: lender eligibility, interest-only or repayment, term, payment stability, minimising early payments, early repayment, other features, credit history, and paying fees upfront	Each factor needs an answer in the file, or a reason it did not apply
MCOB 4.7A.23G	A firm may generally rely on information the customer gives unless a common sense view gives it reason to doubt it	Accept what is credible. Query what is not
MCOB 4.7A.25R	Keep a record of the customer information gathered, for at least three years from the date of the advice	The fact find is part of the record, and three years is a floor

The factor list in MCOB 4.7A.6R is not exhaustive (MCOB 4.7A.7G). Some clients need further questions that the list does not cover.

What the FCA found about information gathering

TR15/9, the FCA's July 2015 review of mortgage advice, is the clearest published view of what good and poor information gathering look like. It predates the Mortgage Credit Directive rules (2016) and the Consumer Duty (2023), so read it as a dated observation, not current statistics. It drew on 134 mystery shops, 34 file reviews and consumer research, and found:

• Preferences decided the outcome. Many advisers gave great weight to a customer's initial preference, such as a fixed rate, and in some cases let it determine the recommendation (paragraph 4.15). The FCA's view was that a preference is an important factor but should not predetermine the assessment, and that needs such as payment stability or low payments still have to be tested against the customer's circumstances (4.16).
• Customers did not volunteer everything. The consumer research behind the review found customers may not offer all relevant information or may downplay future plans. The example given was an intention to have a family, which some customers expected to count against them (4.17).
• Probing worked. The FCA saw more clearly suitable advice where advisers challenged or probed needs and circumstances, particularly where something did not look credible or conflicted with other information (4.18). The best firms asked enough questions to assess needs objectively and discussed trade-offs when preferences conflicted (4.21).
• Challenging everything was not the standard. The review says the rules do not require advisers to challenge everything the customer says (4.20).

The same review found firms that leaned heavily on point-of-sale systems, leaving advisers little room for judgement (paragraph 1.6), and described one firm whose systems-driven fact finding made the process long and disengaging, with prompts for unnecessary questions getting in the way of rapport. It also found oversight that checked the fact find had been completed correctly, with little focus on whether poor outcomes were being caught (paragraph 8.5). A complete form does not, by itself, show that you understood the client.

What to cover

The areas below follow the MCOB 4.7A.6R factors. For the detail on income types, outgoings and credit questions, the onboarding guide covers them step by step.

Area	What to establish	Why it matters
Objectives and priorities	What the client wants the mortgage to do, in their words, and which of those matters most when two conflict	Payment stability, low initial payments, flexibility to overpay and term are all 4.7A.6R factors
Income and its stability	Type of income, how long it has been received, how likely it is to continue, what the lender will accept	The lender will evidence it independently and cannot accept self-certification (MCOB 11.6.8R). See the self-employed income guide
Commitments and outgoings	Actual outstanding credit and other commitments, plus regular household costs	Lenders must take reasonable steps to obtain details of actual commitments (MCOB 11.6.12R), and your recommendation should fit what the client can really carry
Credit history	Missed payments, defaults, CCJs and arrangements the client knows about	4.7A.6R(8) asks whether the contract is appropriate given the credit history the customer discloses
Deposit, fees and costs	Source and amount of deposit, and whether fees will be paid upfront or added to the loan	4.7A.6R(9), and MCOB 4.7A.25R(1)(c) where fees are added
Term and repayment method	How long, interest-only or repayment, and why	4.7A.6R(2) and (3)
Likely changes	Plans for children, career changes, retirement, moving, inheritance, reduced hours	4.7A.19R requires you to explain that suitability rests on current circumstances and reasonably foreseeable changes, so it is sensible to have asked
Property and timescales	Type, tenure, intended use, chain, deadlines, rate expiry	Narrows which lenders are viable and shapes priorities
Existing protection	Cover in place, and what the family would do if income stopped	The start of the protection conversation. See the protection adviser guide
Circumstances that may need support	The FCA's vulnerability guidance (FG21/1) names poor health, life events, low resilience and low capability	Fits within the same conversation. See the vulnerable customers guide

How to probe without interrogating

TR15/9 describes the best firms as asking enough questions to assess needs objectively and probing conflicting preferences. It gives no script, and the examples below are illustrations, not FCA wording.

The client says	A follow-up that tests it
"I want a five year fix"	"What would happen to your plans if you needed to move or repay in year three?"
"We just want the lowest payment"	"If rates rose, what is the most you could comfortably pay each month?"
"My income is steady"	"How has it moved over the last two or three years, and what would change it?"
"Nothing is likely to change"	"Do you expect to have children, change jobs, or reduce your hours in the next five years?"
"No debts apart from the car"	"Any credit cards, buy now pay later, overdrafts or loans you have used in the last year?"

Two points keep this in proportion. MCOB 4.7A.23G lets you rely on what a client tells you unless there is reason to doubt it, so the aim is to follow up where something is thin, conflicting or optimistic, not to challenge every answer. And write the answer down, with the question that prompted it. MCOB 4.7A.25R requires a record of the information you obtained, and a file that also shows what you asked is easier to defend.

Protection fact finds

A protection case rests on different rules. ICOBS 5.2.2R requires you to specify the client's demands and needs, on the basis of information obtained from them, before the contract is concluded. The detail is modulated to the complexity of the contract and the type of customer, and the client must receive a statement of those demands and needs. ICOBS 5.2.2A G confirms that questions in person or a questionnaire are both acceptable ways to gather the information.

For a mortgage client the protection questions often follow naturally from the mortgage ones: dependants, existing cover, what the household would need if income stopped. The protection adviser guide sets out the ICOBS rules and the advice process in full.

Keeping the fact find current

A client who comes back for a remortgage two years later is not the client in the old file. MCOB 4.7A.19R requires you to explain that your assessment rests on current circumstances and reasonably foreseeable changes, and MCOB 4.7A sets no interval after which information must be refreshed. How often to re-confirm each part is a judgement for the firm.

Treat each section separately. A date of birth never changes and a name rarely does. Income, employment, commitments and credit often change, and a change in any of them can change the recommendation. Before reusing an earlier fact find:

• Re-confirm income and employment first, then commitments and credit.
• Ask what has changed since last time, rather than whether the details are still right. An open question tends to surface more than a request for a yes.
• Treat a new event, such as a job change, new borrowing, a child or a move, as a reason to re-ask the sections it affects, whatever the date of the last fact find.
• Date the confirmation in the file, so the record shows when each part was last checked.

How this works in Cleera

Cleera's digital fact-find is built around the approach above.

• Questions follow the answers. The questions a client sees change with what they have already said. An employed client is asked for employer, job title and start date. A self-employed client is asked about trading history, tax years on file and net profit for the last two years.
• Sections are assessed when you assign it. Cleera checks how recently each section of the client's record was captured. A recent, complete section is pre-filled and marked as coming from the client's last application, with the date it was captured. The client confirms each answer, or says something has changed, before they can submit. A section that is incomplete or has gone stale is asked in full.
• The adviser decides. When assigning the fact find to a client, the adviser sees the proposed mode for each section and can override it: force a full capture, set it to review, or leave it out of the form.
• Protection has its own fact finds. Personal and business protection fact finds are available alongside the mortgage one.

Cleera records what the client entered. Judging whether it is credible, and probing where it is not, stays with the adviser. See Cleera's mortgage CRM for how the fact find fits into the case.

Keeping the record

MCOB 4.7A.25R requires a record of the customer information gathered, kept for at least three years from the date of the advice. That is a minimum, and your network or other rules may require longer. The fact find holds the answers. File notes hold the reasoning around them: why you probed, what the client said, and what changed. The guide to writing mortgage file notes covers that side, and the suitability report should only state things the fact find and notes support.

Key takeaways

• MCOB 4.7A asks for reasonable steps to obtain all relevant information, not for a particular form.
• The FCA's 2015 review could not determine suitability in 38% of the mystery shops and files it looked at, because many firms had not taken reasonable steps to obtain enough relevant information.
• A client's first preference is an input, not the answer. Test it against their circumstances.
• You may rely on what a client says unless you have reason to doubt it, so follow up where an answer is thin, conflicting or optimistic.
• MCOB 4.7A sets no refresh interval. Treat each section on its own, and confirm the fast-changing ones first.
• Keep the answers and the reasoning in the record for at least three years.

Sources

• FCA Handbook, MCOB 4.7A: advising on a regulated mortgage contract
• FCA Handbook, MCOB 11.6: the lender's affordability assessment
• FCA Handbook, ICOBS 5.2: demands and needs
• FCA thematic review TR15/9, Embedding the Mortgage Market Review: Advice and Distribution (July 2015)