Client file checklist for advice firms: what to put in order before a compliance file check

Before a compliance consultant, a network or the firm's own reviewer opens a client file, somebody has to make sure that everything which should be in it can be found. This list is for the paraplanner or administrator who does that. It walks one advice file in the order a reviewer reads it: what the firm knew about the client, the meeting records, the suitability report, the evidence of ongoing service and how long the file will be kept. It checks that each item is present and dated. It is written for investment and pension advice files; a pension transfer file needs more than this list covers.

Free tool

Client file checklist before a file check

Tick each step as it is done. The ticks are kept in this browser only, so you can come back to the list; nothing is sent anywhere.

What the firm knew about the client

Check the fact find is dated and covers knowledge and experience, finances and objectives Check attitude to risk and capacity for loss are recorded and matched to the recommendation Check vulnerability was considered and the result recorded, even where none was found File each letter of authority with the provider's reply and the dates of any chases Check the identity documents are on file and dated

Meeting records

Check each meeting note states the date and time, the location and everyone present Check the note says who asked for the meeting and records any instruction, or says none was given Recorded meeting: check the file shows the client was told before the recording began Note drafted by software: check the adviser's name and the date of their check are on it

The suitability report

Check the report states the client's demands and needs, from the information the client gave Check the report explains why the recommendation is suitable for this client Check the report explains any possible disadvantages of the transaction Check costs and charges are shown in pounds and as a percentage, with their cumulative effect Check the alternatives considered are recorded, including the existing arrangement and doing nothing Check the ongoing service is described with its cost and how the client can cancel it Check the date the report was provided against the timing rule for the product Check the adviser has signed the report, including any text a tool drafted

Ongoing service evidence

For each year a fee was charged, find the dated invitation, questionnaire or valuation, and outcome For a year the client declined, find the offer, the decline or silence, and the follow-up offer List any year with a fee and no evidence, and pass it to the adviser and compliance

Retention and hand-over

Mark the file with the minimum retention period under the rule that applies Check the firm's own retention period, where it is longer than the minimum, is on the file Note where each record is held: back office, shared drive, inbox, meeting recorder or paper Write down what was missing, who put it right and the date, before the file goes to the reviewer

Copy what is left Print the list Clear the ticks

A working list, not a certificate and not advice: the rule behind each step, with its source, is set out below. Regulated work: the adviser, and the compliance function where the firm's procedures require it, reviews and signs every client-facing document and every suitability decision; the AI assistant prepares, checks and chases, it never advises.

Works in your browser. Nothing you type leaves this device.

What the firm knew about the client

Check the fact find is dated and covers knowledge and experience, finances and objectives. COBS 9A.2.1R requires the firm to obtain information on the client's knowledge and experience, financial situation including ability to bear losses, and investment objectives including risk tolerance. Compliance can say which chapter, COBS 9 or 9A, each line of business falls under. Source: FCA Handbook COBS 9A.2.1R, read 1 October 2026. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Check attitude to risk and capacity for loss are recorded and matched to the recommendation. This is one of the nine points beyond the COBS 9.4.7R minimum. The list checks that it is present; whether the risk match is right is the adviser's judgement and the compliance function's. Source: our twelve-point file check. The working is in Suitability report file check.

Check vulnerability was considered and the result recorded, even where none was found. Vulnerability considered and recorded is another of the nine points. Health information in a fact find is special category data under Article 9 of the UK GDPR, and vulnerability notes often contain it. Source: FCA FG21/1; UK GDPR Article 9. The working is in AI and client data in an advice firm.

File each letter of authority with the provider's reply and the dates of any chases. The plan information the report depends on comes from providers. A file note showing three dated chases and an escalation at 20 working days is what explains a report or a review that ran late. Source: our chase rhythm for providers. The working is in Letter of authority and document chase email template.

Check the identity documents are on file and dated. Regulation 40 of the Money Laundering Regulations 2017 requires identity and due diligence documents to be kept for five years from the end of the business relationship. After that the personal data must be deleted unless an exception applies. Source: Money Laundering Regulations 2017, regulation 40. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Meeting records

Check each meeting note states the date and time, the location and everyone present. SYSC 10A.1.16R lists what the record of a relevant face-to-face conversation must include: the date and time, the location, the attendees, who initiated the meeting and the details of any client order. Source: FCA Handbook SYSC 10A.1.16R. The working is in Recording client meetings with an AI note taker.

Check the note says who asked for the meeting and records any instruction, or says none was given. For a client order the record needs the price, the volume, the type of order and when it will be transmitted or executed. If no instruction was given, the note should say so in terms. Source: FCA Handbook SYSC 10A.1.9R and 10A.1.16R. The working is in Recording client meetings with an AI note taker.

Recorded meeting: check the file shows the client was told before the recording began. SYSC 10A.1.11R and 10A.1.12AR require clients to be told before any service is provided that conversations will be recorded, and that a copy is available on request for five years to the client and seven to the FCA. Source: FCA Handbook SYSC 10A.1.11R and 10A.1.12AR. The working is in Recording client meetings with an AI note taker.

Note drafted by software: check the adviser's name and the date of their check are on it. The ICO says an organisation using an AI tool for meeting recordings and notes must check that the outputs are accurate and take steps to correct anything that is not. The adviser's dated check is the evidence. Source: ICO innovation advice, previously asked questions. The working is in Recording client meetings with an AI note taker.

The suitability report

Check the report states the client's demands and needs, from the information the client gave. This is the first of the three minimum contents in COBS 9.4.7R. A draft missing any of the three goes back to the drafter before the adviser spends time on it. Source: FCA Handbook COBS 9.4.7R. The working is in Suitability report file check.

Check the report explains why the recommendation is suitable for this client. The second minimum item: why the firm concluded the recommended transaction is suitable, having regard to the client's information. Whether the reasons are good ones is for the adviser and compliance, not for this list. Source: FCA Handbook COBS 9.4.7R. The working is in Suitability report file check.

Check the report explains any possible disadvantages of the transaction. The third minimum item is the one most often missing: reports long on reasons to proceed and silent on what the client gives up. The Consumer Duty's understanding outcome applies to them too. Source: FCA Handbook COBS 9.4.7R; PRIN 2A. The working is in Suitability report file check.

Check costs and charges are shown in pounds and as a percentage, with their cumulative effect. COBS 6.1ZA requires all costs and charges to be added together, shown in cash and as a percentage, with the cumulative effect on return. Our guide sets it out as a table, not a paragraph, with the assumptions stated. Source: FCA Handbook COBS 6.1ZA. The working is in Adviser charging illustration calculator.

Check the alternatives considered are recorded, including the existing arrangement and doing nothing. Alternatives considered is one of the nine points that separate a good report from a minimum one. Whether they were fairly weighed is a judgement for the adviser and the compliance function. Source: our twelve-point file check. The working is in Suitability report file check.

Check the ongoing service is described with its cost and how the client can cancel it. COBS 6.1A.22R allows an ongoing charge only where the client can cancel the service without penalty and without giving a reason. The report should describe the service, what it costs and that right. Source: FCA Handbook COBS 6.1A.22R. The working is in Client not responding to annual review invitations.

Check the date the report was provided against the timing rule for the product. COBS 9.4.4R: for a life policy, before the contract is concluded; for a pension scheme, within 14 days of the contract. A mortgage file falls under MCOB 4.7A instead and records why the mortgage is suitable. Source: FCA Handbook COBS 9.4.4R; MCOB 4.7A. The working is in Suitability report file check.

Check the adviser has signed the report, including any text a tool drafted. The FCA has no AI-specific rules: the existing framework applies, and the adviser is responsible for the recommendation however it was drafted. A report drafted by a tool and signed by an adviser is the adviser's report. Source: FCA AI Update, April 2024. The working is in AI and client data in an advice firm.

Ongoing service evidence

For each year a fee was charged, find the dated invitation, questionnaire or valuation, and outcome. The FCA found reviews delivered in 83% of promised cases and asked firms to look back to 2018. A year counts as delivered only with all three items dated on file. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

For a year the client declined, find the offer, the decline or silence, and the follow-up offer. The FCA's 15% of declined or unanswered reviews covers a year only where the offers are on file. A client who was never asked falls into the not-delivered group, however disengaged they were. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

List any year with a fee and no evidence, and pass it to the adviser and compliance. The FCA asked firms to consider whether redress is appropriate and said it may be partial where some service was delivered. The decision belongs to the firm and its compliance function, with the reason written down. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in Ongoing service tracker for advice firms.

Retention and hand-over

Mark the file with the minimum retention period under the rule that applies. COBS 9.5.2R: indefinitely for a pension transfer, conversion, opt-out or FSAVC; five years for a life policy or personal pension; three years in any other case. Mortgage advice records are three years under MCOB 4.7A.25R. Source: FCA Handbook COBS 9.5.2R; MCOB 4.7A.25R. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Check the firm's own retention period, where it is longer than the minimum, is on the file. Under DISP 2.8.2R the ombudsman can consider a complaint up to six years after the event, or three years from when the client became aware of a cause for complaint. A three-year file destroyed on time is gone three years before that limit. Source: FCA Handbook DISP 2.8.2R. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Note where each record is held: back office, shared drive, inbox, meeting recorder or paper. A reviewer can only check what can be found. The first step in our retention guide is to list where the records are, including any tool that holds a copy of client data. Source: our retention schedule guide. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Write down what was missing, who put it right and the date, before the file goes to the reviewer. A list of what is missing, by rule reference, is what the adviser works from to amend and sign. The compliance function then reviews files on the firm's own sampling basis. Source: our twelve-point file check. The working is in Suitability report file check.

How to use the list

Give the reviewer the finished list with the file, including the note of what was missing and when it was put right. A step left unticked is a finding you made first, which is the purpose of doing this before the check. If the same step is unticked on several files, such as possible disadvantages or the costs table, raise it with the adviser and the compliance function as a pattern in how reports are drafted, not as a slip on one file. Whether the advice was suitable remains their judgement.

A ticked list is a record that the steps were done, not proof that each was done properly. The list covers the points our guides and the official pages named above set out; it is not every duty a firm has. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and this page is general information, not regulatory or financial advice.

Overlyft sets up AI assistants for financial advisers and mortgage brokers: they prepare drafts for a person to approve. They do not tick off any of these steps for you, and you can do every one without them.