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.



FCA Survey – problem question
Michael Senior Compliance 2022, FCA
We wrote recently about the latest FCA survey. This is mandatory and some firms have been querying how to answer one of the questions. The question asks – What are your estimated cash needs (fixed costs, known variable costs) and expected cash inflows between 1 March and 31 May 2022? (GBP) Please report the […]