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.



New pension nudge rules
Michael Senior Compliance 2018, 2022, FCA, Pension, Switch, transfer
One of our clients recently received this note from a SIPP provider. “You may already be aware that 1st June 2022 saw new FCA rules (Policy Statement PS21/21) come into force which require all pension providers to give clients a stronger ‘nudge’, in certain circumstances, towards guidance from the government’s Pension Wise service […]