The Four Stages of the Advice Process

How CeMAP advice flows from fact find to implementation under Consumer Duty.

Under the 2025/26 CeMAP syllabus, the advice process follows four key stages designed to ensure advice is suitable, compliant, and in the client's best interests under FCA Consumer Duty expectations.

1. Gathering Information ("Fact Find")

Purpose: to fully understand the client's situation across the areas below.

Personal circumstances — Family setup, employment and overall situation.
Financial position — Income, outgoings, savings, debts and assets.
Objectives and priorities — For example, buying their first home or wanting payment certainty.
Attitude to risk — Whether they want high or low risk, including uncertainty, financial risk and potential changes to their circumstances.
Existing commitments — Such as children and other dependants.
Protection arrangements — Whether they already have insurance policies in place.

Adviser's tasks (Stage 1)

Complete a fact find.
Verify the client's identity and income.
Assess their affordability.
Identify their needs and vulnerabilities.
Explain the service and disclosure documents.

Key documents (Stage 1)

Fact Find — Record of the client's circumstances and objectives.
ID & verification documents — Used to confirm the client's identity.
Income/expenditure evidence — For example, bank statements.
Initial Disclosure / IDD — Documents explaining the mortgage advice process and the details of the mortgage advice.

2. Analysing & Assessing Needs

Purpose: to evaluate the client's situation and identify suitable solutions.

Adviser's tasks (Stage 2)

Analyse affordability and eligibility.
Assess risks.
Research suitable mortgage and protection products.
Prioritise client objectives.
Consider repayment methods and term suitability.

Main considerations (Stage 2)

Income stability.
Credit history.
Loan-to-value (LTV).
Interest rate preferences.
Future changes in circumstances.

3. Recommendation & Presentation

Purpose: to recommend the most suitable solution and explain why.

Adviser's tasks (Stage 3)

Present recommendations clearly.
Explain risks and benefits.
Justify suitability.
Explain costs, fees and charges.
Ensure the client understands the implications.

Key requirements (Stage 3)

Recommendations must be:

Clear.
Fair.
Not misleading.

Key documents (Stage 3)

Suitability Letter / Recommendation Report.

4. Implementation & Review

Purpose: to put recommendations into action and maintain ongoing suitability where applicable.

Adviser's tasks (Stage 4)

Submit the mortgage application.
Liaise with lenders, solicitors and insurers.
Monitor progress to completion.
Arrange reviews if an ongoing service exists.

Important areas (Stage 4)

Record keeping.
Compliance evidence.
Treating customers fairly.
Updating clients on progress.

Key regulatory principle

The entire advice process is built around:

Suitability.
Consumer Duty.
Treating Customers Fairly (TCF).
Acting in the client's best interests.

Key revision points

Stage 1 (Fact Find): gather personal, financial and risk information; verify ID and assess affordability.
Stage 2 (Analyse & Assess): evaluate eligibility, risk and product options against client priorities.
Stage 3 (Recommend & Present): give clear, fair, not misleading advice with a Suitability Letter.
Stage 4 (Implement & Review): submit, liaise with third parties, keep records and review where applicable.
The whole process is anchored in Suitability, Consumer Duty, TCF and the client's best interests.

← Back to topics Next: Applied Regulation