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.



An ATEB reminder for all staff involved in insurance distribution activities
Michael Senior Compliance Conduct, FCA, P1, PI, Security
We thought it appropriate to issue a New Year reminder for firms that have staff … directly involved in the carrying on of the firm’s insurance distribution activities; or within the management structure responsible for the firm’s insurance distribution activities; or responsible for the supervision of a relevant employee acting in the capacity […]