Many reports we view are still over engineered with a subjective choice of hard fact content that is simply not crucial to explaining suitability. Fundamentally reports need to explain why advice is suitable. In our view, structure and content should reflect a ‘TCF friendly’ output. Ideally this could involve using short paragraphs, clear headings and summaries. The ‘order of play’ should highlight the key reasons early and remember this is not necessarily the sales process order.
Don’t forget, you don’t need to regurgitate ‘what you did’ in these reports. If you want to send the client a bible of what you did then feel free to do this at your leisure and convenience we can however assure you that it’s not a regulatory requirement.



Consumer Duty: It’s a matter of Principle
Huw Reynolds Compliance Conduct, FCA, PI, protection
Apologies for the Consumer Duty overload but unless you’re taking a regulatory sabbatical, this is very much a hot topic. There are in excess of 50 FCA Handbooks (rules and guidance). You cannot be expected to be conversant with all of them, but you should have a good handle on the key ones, such […]