Mortgage broker client communication policy

Most brokerages have never written down how they communicate with clients, and it shows in ways that are easy to miss from the inside. One adviser answers WhatsApp messages at ten at night. Another takes three days to return a call. A client is told something in a corridor conversation that never reaches the file. Nobody is doing anything wrong, exactly, but the firm is inconsistent, and inconsistency is where both service problems and evidence problems begin.

A communication policy is a short internal document that settles a handful of questions once, so that nobody has to decide them case by case.

Channels: decide which ones you are actually on

The first question is which channels your firm uses. Not which ones exist — which ones you commit to monitoring and recording.

Be honest about what is happening in practice. If advisers are using their personal mobiles for client calls and texts, that is a channel, whether or not it is in a policy. The question is whether you bring it inside the firm's systems or stop it.

For each channel you allow, settle four things: who monitors it, during what hours, what response time applies, and how the content reaches the case file.

That last point is where messaging apps cause difficulty. A conversation on a personal messaging app that never lands in the case record is a gap in your evidence, and it is a data protection issue too, since client personal data is then sitting on a device the firm does not control. Firms that allow messaging typically either use a business version that archives to the case, or require the adviser to summarise into the file immediately afterwards.

Response standards

Set maximums, not aspirations, and set them from what you currently achieve rather than from what would impress a client.

Cover at least these:

• New enquiries, which should be tighter than everything else because response speed drives conversion more than anything else you control.
• Existing client emails and voicemails during working hours.
• Contact arriving outside working hours, including what your automatic reply promises. If it says someone will respond shortly and shortly means Monday, change the wording.
• Urgent matters, with a definition of urgent that is not left to the client's judgement alone.
• Complaints, which have their own required handling and should not be governed by your general response standard.

Proactive contact: the part that matters most

Reactive standards are the easy half. The half that changes client experience is deciding when you contact clients without being prompted.

Write down the moments where contact is automatic: on submission, at a defined interval during underwriting, when a valuation is instructed, when an offer arrives, ahead of an offer expiry, at completion, and ahead of a product end date.

Then add the rule that carries the whole thing: an update is sent on schedule whether or not there is news. Most inbound client chasing exists because firms only make contact when something has happened.

Recording

Every substantive client contact needs to reach the case record. Not the inbox — the case.

Set the expectation clearly. Calls get a note the same day. Emails are filed to the case automatically wherever the system supports it. Meetings get a summary. Anything agreed with a client gets confirmed in writing, which is both good service and a timestamped record.

Where a conversation involved a decision, a reassurance, or anything the client might later rely on, the note should say what was said rather than that a conversation took place.

Tone and clarity

Consumer Duty puts real weight on whether clients understand what they are being told, not just on whether they were told it. That makes writing style a legitimate policy matter rather than a matter of taste.

A few standards worth agreeing across the firm:

• Explain any term the client has not used first themselves.
• Put the point in the first sentence rather than building up to it.
• Where something will cost the client money, say the amount in figures.
• Avoid softening bad news to the point where the client does not realise it is bad news.
• Where an explanation is complex, follow the conversation with a written summary.
• Ask the client what they want to know rather than assuming.

Check occasionally by reading your own outbound emails as a stranger would. Firms are consistently surprised by how much jargon has crept in.

Vulnerability and communication preferences

Your policy should say how communication adapts when a client has additional needs. Capture preferences at the outset: preferred channel, preferred time, whether someone else should be included in conversations, whether written follow-ups are wanted as standard.

Then make sure those preferences are visible to anyone who might contact the client, including administrators and cover staff, before they pick up the phone. A recorded preference that nobody sees is not an adjustment.

Who says what

Define what unregulated staff may and may not say. Administrators will be asked advice questions constantly, and they need a comfortable way to decline that does not sound like a brush-off, plus a clear route to get an answer quickly.

If you are an appointed representative, your network sets these boundaries and also usually controls what client-facing material may say. Their rules take precedence over anything you write locally. If you are directly authorised, you set them and carry the responsibility.

Absence and cover

State who covers whom, how clients are informed, and what the covering person is authorised to do. An out-of-office that names nobody is a policy failure, because the client is left with no route in.

Review it against reality

Once a year, pull a sample of recent cases and check what actually happened against what the policy says. Look at response times, at whether the scheduled updates went out, and at whether contact reached the file.

The gap you find is the real policy. Either close it or change the document, but do not leave a policy in place that the firm demonstrably does not follow.

A note on scope

Complaint handling, financial promotions, record retention and data protection all have specific requirements that sit above anything you write here. Confirm those through the FCA Handbook, the ICO's guidance and your compliance support. This is an operational framework for consistency, not compliance advice.