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 – FCA information and help
Shirley McKenzie Compliance FCA, PI, Update
The FCA has added to its published information relating to Consumer Duty to help firms with implementation. The most recent addition to the Consumer Duty webpages is an information for firms page to help firms implement the Duty. This explains more on the areas of the Duty that firms have been raising queries […]