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.



Identify, Assess & Manage
Steve Bailey Compliance FCA
Before you read on, what do you think the title refers to? The answer is Business Risks. The FCA has been highlighting this issue in workshops. They expect firms to ‘Identify, Assess & Manage’ risks and to be able to provide documentary proof that they are so doing. They expect firms to have at least […]