How to structure client records, households, and communication in a UK mortgage brokerage — with Consumer Duty and vulnerability properly embedded.
A mortgage application is household-level: two applicants, joint income, joint liabilities. A CRM that forces you to manage each applicant as a separate contact generates duplicate work and suitability gaps. Model the household as the primary entity; individuals are members.
Under FG21/1, firms must embed vulnerability into every stage of the customer journey. At the record level this means: four-driver assessment (health, life event, resilience, capability) captured at fact-find, re-prompted at recommendation, and re-evaluated at any life-event trigger.
Every outbound communication is a regulatory artefact. Capture the channel, the content, who sent it, who approved it (if automated), and any client response. Under Consumer Duty, firms must evidence that communications support understanding.
MCOB 4 requires suitability records for a minimum of three years; in practice firms should retain for the life of the relationship plus six. Your CRM must meet this without manual export. Retention must be defensible to the ICO under UK GDPR's storage-limitation principle.
A well-managed client returns at remortgage (every 2-5 years), upsizes for protection, and refers. The CRM should prompt each of these touchpoints automatically — not sit silent between cases.
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