Mortgage Brokers
Two business days. That is what MCOB gives you.
MCOB records must be available to the FCA within two business days of any request. My records are across a CRM, email threads and client files. I know I could compile them — but not in two business days under investigation conditions.
Evidentia is built so suitability, affordability and Consumer Duty monitoring are sealed when they happen — not assembled when the clock is running.
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The regulatory landscape
Mortgage intermediaries are subject to MCOB conduct of business rules, including rigorous record-keeping and file standards. The FCA can request records with short deadlines; delay or patchwork production is itself a supervisory signal.
Consumer Duty applies end-to-end: intermediaries must be able to show fair value, appropriate communication, and good outcomes — with evidence that monitoring is real.
Recent market-wide reviews (including motor finance) demonstrate how undocumented commercial structures and suitability reasoning become multi-billion-pound remediation problems. Mortgage intermediaries are not immune from the same documentary scrutiny.
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What regulators look for
File reviewers test affordability reasoning, fee disclosure, product selection, and whether vulnerable customers received appropriate adjustments. Missing notes are treated as missing advice.
Under MCOB, the FCA expects complete records quickly. Inspectors know when a file has been reconstructed — metadata and date gaps tell the story.
Consumer Duty oversight must be evidenced at SMF level where applicable — not delegated into a black box.
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What Evidentia gives you
Two-day retrieval posture
Suitability, affordability and disclosure records sealed and indexed — produced as a pack, not a panicked search.
Consumer Duty monitoring entries
Each monitoring act recorded with data reviewed, decision, and owner — the pattern supervisors ask for.
Immutable advice trail
Tamper-evident chain for critical records — integrity demonstrable to the FCA without proprietary forensics.
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The evidence gap
Most brokers we speak to are diligent under time pressure. The weakness is fragmentation: CRM fields, email, lender portals and paper notes do not form a single defensible file when the FCA sets a 48-hour clock.
Reconstruction under stress produces inconsistencies — inconsistencies become findings.
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Key enforcement facts
MCOB requires records to be available within two business days of an FCA request — investigation conditions are not an excuse.
The FCA's motor finance redress scheme illustrates how undocumented structures scale into sector-wide liability.
Consumer Duty supervision now tests evidence of outcomes — not policy attestations.
Find out whether your current approach would withstand scrutiny.
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