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 starts to take hold
Lisa Cross Compliance
Consumer Duty rules will take full effect from 31 July 2023. However, it is starting to show its face already. This message is now appearing on Connect in some circumstances. “The majority of firm types that need to apply for authorisation or existing firms seeking to vary their permissions will need to comply with […]