COMPLIANCE

FCA Consumer Duty: What Your CRM Should Track

The Consumer Duty requires demonstrable outcomes. Here's how your CRM should capture evidence of fair value, understanding, and support.

7 min read · 20 Feb 2026

The Consumer Duty Challenge

Since July 2023, the FCA's Consumer Duty has required firms to demonstrate they're delivering good outcomes for clients. This isn't just about having the right policies — it's about evidence. Your CRM is the primary tool for capturing that evidence.

Many mortgage brokers underestimate the documentation requirements. It's not enough to do the right thing — you need to prove you did. A CRM with built-in compliance workflows makes this automatic rather than burdensome.

Four Outcomes Your CRM Must Track

1. Products and Services

Track why specific products were recommended. Your CRM should capture the rationale behind every recommendation, linking it to the client's specific circumstances and needs.

2. Price and Value

Document fair value assessments. If a client is paying a higher proc fee, record why that product still represents fair value for their situation.

3. Consumer Understanding

Log how you've ensured the client understands the product. This includes recording the format of communications, readability checks, and confirmation of understanding.

4. Consumer Support

Track vulnerability assessments, accessibility accommodations, and post-sale support. Your CRM should flag clients who may need additional support and log the actions taken.

Building an Audit-Ready Firm

The firms that thrive under Consumer Duty aren't doing anything dramatically different — they're just documenting it properly. A CRM that automates this documentation turns compliance from a burden into a competitive advantage. Learn how Adviser IQ helps.

FAQ

What does the FCA Consumer Duty require from mortgage brokers?

The Consumer Duty requires mortgage brokers to demonstrate good outcomes across four areas: products and services, price and value, consumer understanding, and consumer support. CRM systems should capture evidence for each.

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