Mortgage AI and automation for brokers
Much of the mortgage AI a broker meets arrives inside systems it already runs: Acre announced an AI meeting assistant and document checker in February 2026, Smartr365 has its MAIA assistant, and Knowledge Bank suggests criteria areas as brokers type. We build the work between those systems, with an adviser deciding every recommendation.
The FCA says it does not plan extra rules for AI, as the Consumer Duty and the Senior Managers and Certification Regime already apply. In its December 2025 Mortgage Rule Review feedback, respondents agreed that qualified advisers should review and sign off AI-based recommendations. Whoever drafts it, the suitability record stays the firm's.
Where the time goes
Fact-find and documents
Fact-finds are gathered in meetings, on video calls and through client portals, then documents chased, read and filed. Advice rests on the client's disclosures, which the adviser can generally rely on unless there is reason to doubt them, and on what the firm should reasonably know.
Sourcing and criteria
Each case is checked against lenders' known eligibility criteria, including expected affordability, weighing repayment type, term, payment stability and fees. If the deal is not the cheapest suitable one in range, the adviser must explain why.
The suitability file
Each advised case needs a record of the client's needs and circumstances and of why the advice is suitable, kept for at least three years, with any choice to add fees to the loan. Protection adds a demands and needs statement.
Applications and chasing
Decisions in principle and applications go through lender portals, often re-entering what the CRM already holds. Iress says disconnected systems and manual rekeying still slow brokers and lenders down, and built its Lender Connect API to cut it.
The systems you already run
Acre
A mortgage and protection CRM, bought by ClearScore Group in January 2026. In February 2026 it announced a Meeting Assistant that transcribes meetings, flags vulnerabilities and checks the fact-find, and a Document Checker. We found no public API documentation.
Twenty7tec
RESEARCH sources products, criteria and affordability and applies to participating lenders; Twenty7tec says its two-way open API links it to CRM and onboarding. Since October 2026, PlannerPal turns meetings into notes and letters filed in its ADVICE CRM.
Mortgage Brain
Its Hub brings together sourcing, criteria, affordability, CRM and submissions, and Submissions Brain also works with other CRMs. Its April 2026 AI Charter says client data is not shared with external AI providers.
Iress
Behind Xplan Mortgage, Trigold and The Exchange, Iress offers Mortgage and Protection Sourcing APIs for your own CRM, and its Lender Connect API pre-fills decisions in principle with lenders including Nationwide and Coventry.
Smartr365
A platform covering fact-finds, sourcing, protection, documents and retention, with the MAIA assistant for reminders and routine tasks. Its published Leads API lets introducers push leads into a brokerage.
What we would build
Meeting to fact-find
Turns a recorded meeting, with the client told, into a draft fact-find update and file note in your CRM, showing gaps, conflicts with the file and possible signs of vulnerability for the adviser to confirm.
Document checks
Reads ID, payslips and bank statements from the portal or inbox into the case, compares them with the fact-find and lists what is missing for an automatic chase. An administrator clears every flag.
Suitability letters from your template
Drafts the letter from the fact-find, sourcing results and adviser's notes: why this deal, why not a cheaper suitable one, any fees added to the loan. The adviser edits and signs it off; every version is kept.
One record across systems
Moves fact-find data from your CRM into sourcing and lender applications through their APIs, pulls case status back, watches deal end dates for reviews, and builds the outcome reports your board or principal asks for.
Where AI helps
AI should not choose the mortgage or the cover: recommending a product is advice, which MCOB 4.7A and ICOBS 5.3 govern. Nor should it label a client vulnerable or turn anyone away by itself, as UK GDPR Articles 22A to 22D set safeguards for significant decisions without meaningful human involvement.
- Turning a recorded meeting into a draft fact-find and file note, with the adviser checking each field.
- Reading payslips, bank statements and ID and flagging mismatches with the fact-find, for an administrator to clear.
- Drafting suitability letters and protection demands and needs statements from your templates, with the adviser signing off each one.
How we would start
We would start with one adviser's cases: where the fact-find comes from, which documents get chased, and how the reasons for each recommendation reach the file. The first working version would connect to your mortgage broker CRM, turn a recorded meeting into a draft fact-find and file note, and draft the suitability letter from your template, with the adviser approving each one and every step logged.
That first stage, the design and a written scope, typically takes one to three weeks. Like every stage, its price is fixed and agreed before it starts, and you can stop after it. How a project runs
Rules we build around
The software keeps the records these ask for. The duties stay with you.
MCOB 4.7A (advised sales)
Advice must be suitable, weighing the lender's known eligibility criteria, repayment type and term (4.7A.6R). If the deal is not the cheapest suitable one in range, explain why (4.7A.23AR). Keep the client information and reasons for at least three years (4.7A.25R).
Consumer Duty (PRIN 2A)
A firm must regularly monitor the outcomes clients get from its products, communications and support, spot groups doing worse, and find root causes (PRIN 2A.9). At least yearly its governing body must approve a report on those outcomes (PRIN 2A.8.4R).
ICOBS 5.2 and 5.3 (protection advice)
Before a policy is concluded, the firm must specify the client's demands and needs from information it obtains and give them a statement (5.2.2R). Advice needs reasonable care over suitability (5.3.1R), with a personalised explanation of why the policy best meets them (5.3.4R).
UK GDPR Articles 22A to 22D
In force since 5 February 2026 under the Data (Use and Access) Act 2025. A significant decision with no meaningful human involvement needs safeguards: telling the client, and letting them make representations, get human intervention and contest it. Health details are special category data (Article 9), which narrows this further (22B).
Financial crime controls
The FCA says mortgage brokers are not bound by its AML rules or the Money Laundering Regulations 2017, but still need controls to prevent financial crime. The Regulations cover insurance intermediaries acting on long-term insurance (reg. 10(2)(f)), except occasional or very limited activity (reg. 15), so check where arranging life cover puts you.
Questions
Our CRM already has AI. Do we need anything else?
Often not. If Acre's Meeting Assistant, Smartr365's MAIA or PlannerPal in Twenty7tec ADVICE does the job, using it is the better answer. We build what sits between your systems: inboxes, document checks, letters in your template, rekeying into lender portals and reports assembled by hand.
Can AI give mortgage advice?
Since 22 July 2025 a firm can discuss options without automatically triggering advice, as PS25/11 removed the interaction trigger. A tool that recommends a product is still advising, so MCOB 4.7A applies, and firms must consider how to spot execution-only customers who need advice (MCOB 4.8A.4A).
We are an appointed representative. Can we add our own tools?
Ask your principal first. It oversees your business, must review you at least every 12 months, and reports complaints and revenue data for its appointed representatives each year. We would build around the systems it approves and give it the records it needs.
What do the FCA's 2026 mortgage proposals mean for our systems?
CP26/18 (June 2026) proposes changes for interest-only, retirement interest-only, variable incomes, past credit problems, foreign currency loans and bridging; the FCA aims to publish a policy statement in the second half of 2026. For interest-only repayment plans, lenders could ask intermediaries to run a tailored interactive dialogue, even by SMS or email, with the intermediary answerable for the accuracy of what it passes on.
Sources
Every rule, date and figure on this page comes from the sources below, checked on 31 October 2026. Rules change: check anything that matters with the source or your adviser.
The 30 sources
- Mortgage Solutions: Acre releases AI-powered meeting and document checking features (23 February 2026)
- Smartr365: MAIA, AI-powered assistant for mortgage advisers
- Mortgage Solutions: Knowledge Bank brings out AI tool for criteria search (21 August 2025)
- FCA: AI and the FCA: our approach (updated 2 October 2026)
- FCA: FS25/6 Mortgage Rule Review: feedback to DP25/2 and roadmap (December 2025), paragraphs 4.22 to 4.27
- FCA Handbook: MCOB 4.7A Advised sales
- Smartr365: home page (platform, Smartr Retain)
- Mortgage Brain: home page (Mortgage Brain Hub, Submissions Brain)
- FCA Handbook: ICOBS 5.2 Demands and needs
- Iress: Lender Connect
- Mortgage Solutions: ClearScore Group expands footprint in mortgage market with Acre acquisition (23 January 2026)
- Twenty7tec: RESEARCH mortgage sourcing software
- FF News: PlannerPal integrates AI workflow into Twenty7tec ADVICE for mortgage advisers (20 October 2026)
- Mortgage Brain: AI Charter (21 April 2026)
- Iress: Sourcing APIs and integrations
- Smartr365: Leads API (OpenAPI documentation)
- FCA Handbook: MCOB 4.8A Execution-only sales
- legislation.gov.uk: UK GDPR, Article 22A
- FCA Handbook: PRIN 2A.9 Monitoring of consumer outcomes
- FCA Handbook: PRIN 2A.8 Governance and culture
- FCA Handbook: ICOBS 5.3 Advised sales
- legislation.gov.uk: Data (Use and Access) Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, regulation 2
- legislation.gov.uk: UK GDPR, Article 22C
- legislation.gov.uk: UK GDPR, Article 9
- legislation.gov.uk: UK GDPR, Article 22B
- FCA: Money laundering and terrorist financing (updated 11 February 2026)
- legislation.gov.uk: Money Laundering Regulations 2017, Part 2 Chapter 1 (regulations 8 to 15, including 10(2)(f) and 15)
- FCA: PS25/11 Mortgage Rule Review: first steps to simplify our rules and increase flexibility (22 July 2025)
- FCA: Responsibilities and how to oversee your appointed representatives (updated 26 November 2025)
- FCA: CP26/18 Mortgage Rule Review: supporting first-time buyers and underserved consumers (June 2026)
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