Mortgage File Check Before Submission: A Checklist

A pre-submission check is the last review of a mortgage file before it goes to the lender. Its purpose is to catch gaps and mismatches while they are still cheap to fix, and to leave evidence that someone looked. This guide gives a checklist you can use as it stands or adapt, explains what the rules do and do not require, and covers who should do the check and how to make it routine. The last section covers how Cleera supports it.

What the rules say

No rule in the sections checked for this guide asks for a pre-submission check by name. The ones that bear on it are these:

• Systems and controls. SYSC 3.2.6R requires a firm to take reasonable care to establish and maintain effective systems and controls for compliance with applicable requirements. SYSC 1 Annex 1 sets out how SYSC applies to different firms and activities, so confirm with your compliance adviser or network how it applies to you. Where it does, a check before submission is one way to show those controls work in practice.
• Suitability and records. MCOB 4.7A requires reasonable steps to obtain the relevant information and advice that is suitable, and MCOB 4.7A.25R requires a record of the customer information gathered and of why the advice complied, kept for at least three years from the date the advice or explanation was given.
• Reliance. MCOB 4.7A.23G lets a firm generally rely on what the customer tells it unless, taking a common sense view, it has reason to doubt it. A file check is where doubts, such as a figure that does not match a document, get caught.
• Outcomes. PRIN 2A.9.8R requires firms to regularly monitor the outcomes retail customers receive. A file check looks at one case; outcomes monitoring looks across them. The outcomes monitoring guide covers the second.

The FCA has also said what a weak check looks like. TR15/9, its July 2015 review of mortgage advice, drew on 134 mystery shops, 34 file reviews and consumer research. It predates the Mortgage Credit Directive rules (2016) and the Consumer Duty (2023), so treat it as a dated observation. 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 (paragraph 1.5). It also described oversight that checked the fact find had been completed correctly, with little focus on whether poor outcomes were being caught (paragraph 8.5). So a good check looks at what the file says and whether the advice follows from it, not only at whether every box is ticked.

The checklist

Use this as a starting list and shorten it to what your firm actually reviews. Each row is a question, with what to look for in the file.

Area	Check	What the file should show
Client information	Is the fact find complete, dated and current for this application?	Every section filled in, with dates, and anything that changed since it was taken noted
Conflicts	Does anything in the file contradict something else?	Differences between the fact find, documents and application raised with the client and explained
Objectives	Are the client's objectives and priorities in their own terms?	What they want the mortgage to do, and which priority wins when two conflict
Income and evidence	Do the documents support the income declared, for the way the client is paid?	Payslips, accounts or tax documents that match what was declared, and in date
Commitments and credit	Are commitments and credit history current and discussed?	Up-to-date commitments, and any adverse markers recorded with what the client said
Identity and checks	Is identification in date, in the right name, and verified as your procedures require?	A named, current document matched to the applicant, with the check recorded
Recommendation	Does the advice follow from the information, and is the reasoning written down?	A suitability report or note that explains why this product, lender and term
Fees and commission	Have fees and any commission been explained and recorded?	A record of what was disclosed and when
Vulnerability	Has anything that might affect the client's ability to understand or decide been noted?	What was seen, what was done about it, and who was told
Protection	Has protection been discussed and the outcome recorded, including a decision not to take it?	The client's position and the reasoning, whichever way it went
Notes and audit	Can someone else follow what happened?	File notes with dates, and a clear order of events

The point of the table is to prompt a judgement, not to produce a tick. A row that is ticked but cannot be backed up by something you can point to in the file is not done.

Who checks, and how often

There are three ways to set this up, and a firm can use more than one.

• The adviser, against a list. Quick and always available, but the adviser knows what they meant, so they tend to read what they intended.
• A second person on every case. A paraplanner or another adviser reads the file cold. It is the most thorough route and the most costly in time, so firms often reserve it for the cases that carry more risk, such as complex income, adverse credit or a limited company purchase.
• A sample. A compliance officer or senior adviser checks a selection and records what they found. The rules and guidance read for this guide give no figure for how many files to sample, so the share and how files are chosen are for the firm to set and defend.

If you are an appointed representative, your network or principal may require its own checks. Follow theirs, and use anything here as an addition, not a substitute.

Making it routine

• Keep the list short. A list that is too long gets skimmed. Put the checks that catch real problems at the top.
• Do it before submission, not after. The same finding is cheaper to fix with the client on the phone than after the lender has asked.
• Record the outcome. Who checked, when, what was found, what was fixed. A check you cannot show was done is hard to rely on later.
• Read the findings together. A problem that keeps appearing, such as out-of-date income documents, is a process issue, not a one-off. The management information guide covers turning those into measures.
• Review the check itself. If it never finds anything, ask whether it is looking at the right things.

How this works in Cleera

Cleera helps you find the gaps before you submit. It flags and suggests; the adviser decides what to do, and the file check itself stays with you.

• Risk flags on the case. The case view shows risk flags, with the most serious first, each with a suggested next step. The rules behind them include high loan to value, an adverse credit profile, a chain under deadline pressure, a target completion date that is close or has passed, a case with no recent activity, and a client document that has expired or is about to. Protection cases have their own flags, such as cover below the mortgage, cover that ends before it, dependants with no cover recorded, and details missing for a quote.
• AI suggestions. The AI suggestions panel pulls the case's risk flags, document needs and gaps in the client's record into one list. It checks, for example, for a missing date of birth, National Insurance number, current address, employment or income. It can suggest requesting a document, messaging the client, creating a task or noting a risk. Nothing is saved until an adviser approves, edits or dismisses it.
• Uploaded documents are read. When a client uploads a document, Cleera summarises it, lists any concerns and recommends approve, review or reject.
• Is the request complete? For a document request such as "last three months of bank statements", Cleera checks whether what the client uploaded covers everything the request asked for, and lists what is missing. It is advisory: the adviser approves or rejects each upload.
• Suitability notes are drafted from the case and checked before they are finalised. Cleera drafts the note from what is on the case. Where the record is silent on a point, it leaves an "Adviser to confirm" prompt instead of filling the gap with generic wording. The adviser can edit every section while the note is a draft, and Cleera records who last edited it and when. The note is finalised only once every prompt has been dealt with, no section is empty, and the adviser has confirmed they have reviewed each section, so gaps and unread sections are caught before the note is locked. That confirmation, and who finalised the note and when, are recorded. The suitability report guide covers it in more detail.
• A record of what happened. Status changes and approvals are kept in the case's audit log.

These features are part of the AI tools on the Solo Pro and Firm plans. Cleera drafts, flags and organises; judging whether the file is ready to submit stays with the adviser. See Cleera's mortgage CRM for how the case record fits together.

Takeaways

• No rule read for this guide asks for a pre-submission check by name, but SYSC 3.2.6R (where it applies) expects effective controls, and MCOB 4.7A expects suitable advice and a record of it.
• Check substance, not only completeness. The FCA's 2015 review criticised oversight that checked the form was complete and not whether poor outcomes were being caught.
• Use a short list, a second reader for riskier cases, and a record of what was found.
• Follow your network's requirements first if you are an appointed representative.
• Treat repeated findings as a process problem to fix, not a series of one-off errors.

Sources

• FCA Handbook, SYSC 3.2: Areas covered by systems and controls (including 3.2.6R)
• FCA Handbook, SYSC 1 Annex 1: Application of SYSC
• FCA Handbook, MCOB 4.7A: advising on a regulated mortgage contract (including 4.7A.23G and 4.7A.25R)
• FCA Handbook, PRIN 2A.9: Monitoring and review (including 2A.9.8R)
• FCA thematic review TR15/9, Embedding the Mortgage Market Review: Advice and Distribution (July 2015)