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.



Financial Sanctions Checks
Shirley McKenzie Compliance Conduct, FCA, PI
In response to Russia’s invasion of Ukraine, the FCA published information about the tranche of sanctions announced in relation to Russia and Belarus and the HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has been regularly updating its publications to provide new information as it becomes available. Financial sanctions – a firm’s obligations The FCA […]