What the FCA actually requires UK mortgage advisers to keep, for how long, and how to switch CRM platforms without putting any of it at risk.
Written by
Charlotte BrownRole
Mortgage Industry Writer
Most advisers who've thought about switching CRM have also talked themselves out of it, usually at the same point in the conversation: what happens to everything already in the old system. Years of case notes, client documents, KFIs, communication logs. The current platform might be clunky, slow, or missing half of what a modern firm needs, but at least the history is there. Moving it feels like the kind of risk that isn't worth taking.
That fear is reasonable. It's also mostly solvable, provided you know what you're required to keep, for how long, and what a proper migration looks like before you commit to one.
Most advisers assume there's a single retention rule covering mortgage case records. There isn't. The FCA's MCOB sourcebook sets different retention periods for different types of record, and the gap between the shortest and the longest is bigger than most firms expect.
Key facts illustrations and offer documents need to be kept for one year. Customer information gathered to assess suitability, along with records of arrears and payment-difficulty discussions, needs three years. Responsible lending documentation, the evidence showing how you assessed affordability under MCOB 11.6.60R, needs to be kept for the entire term of the mortgage contract. On a 30-year mortgage, that record has to survive for 30 years, not three.
That last one is the detail that should change how a firm thinks about switching platforms. A CRM that quietly drops or corrupts old case files isn't just losing convenient reference material. Depending on the record, it could mean a firm can no longer evidence how it complied with FCA rules on a mortgage that's still live, potentially decades after the sale.
Outright data loss during a migration is rare. What happens more often is quieter and easier to miss during due diligence.
Notes and communications logs get exported as flat text and lose their original timestamps, so a record that used to prove exactly when advice was given now just shows an import date. Documents migrate but lose the metadata that tied them to a specific case stage. Custom fields a firm built for its own workflow don't map to anything in the new system, so the data either gets dropped or dumped into a single unsearchable notes field. The audit trail itself, the sequence that shows what happened and when, breaks even when the underlying files technically survive. That sequencing matters for its own reasons: under SYSC 9, firms have to keep records in a form that lets the FCA "reconstruct each key stage" of a transaction, not just retain the underlying documents.
None of that shows up on day one. It shows up months later, when a file review or a complaint requires reconstructing exactly what happened on a case, and the record that should answer the question doesn't quite hold together anymore.
A few concrete questions, asked of any vendor before signing anything, catch most of the risk above.
It's a useful check against Cleera's own evaluation framework, which recommends asking similar questions of any CRM, migration included. Firms that skip this step usually aren't skipping it out of carelessness. It just doesn't feel like the priority when you're comparing pipeline views and pricing tiers. It should be, because it's the part of the decision that's hardest to undo once you're partway through.
A one-to-three-adviser firm doesn't need a formal project plan to switch CRM safely, but it does help to treat the migration as a distinct step rather than something that happens automatically the moment you sign up.
None of this needs to take long. It just needs to happen deliberately, with someone checking the detail, instead of assuming it went fine because nothing broke on the surface. If spreadsheets rather than a prior CRM are what you're moving away from, the considerations are different again, and that's covered separately.
How long does the FCA require mortgage advisers to keep case records? It depends on the record type. Key facts illustrations need one year, suitability and arrears records need three years, and responsible lending and affordability documentation needs to be kept for the full term of the mortgage contract, which can mean 25 to 35 years.
Can I lose data during a CRM migration and not notice straight away? Yes, and it's more common than outright data loss. Timestamps, audit-trail sequencing, and custom field mappings are the parts most likely to degrade quietly during a migration, often surfacing only when a specific case is reviewed months or years later.
Should I keep my old CRM running after I switch? Keeping read-only access for a period after go-live is good practice, particularly for a small firm without dedicated IT support to fall back on if something is missing from the migration.
What should I ask a new CRM vendor about data portability? Ask what format your data exports in if you ever need to leave, whether timestamps and audit-trail detail are preserved during migration, and how their retention policy lines up with FCA record-keeping requirements rather than just their own backup schedule.
Is switching CRM worth the risk for a small mortgage firm? Usually yes, if the current system is genuinely holding the firm back, but the risk is worth taking seriously rather than dismissing. A short, deliberate migration process with parallel running and spot-checks removes most of the actual risk involved.
If you're weighing up a switch and case history is the thing holding you back, that's a reasonable place to want clear answers before deciding anything. Cleera's audit trail is built around exactly the kind of long-term, MCOB-aligned record-keeping this piece describes. Get in touch if you want to talk through what moving your existing cases across would involve.
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