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.



AR survey
Michael Senior Compliance 2021, complaints, Conduct, email, EU, FCA, scam, Xplan
The FCA is requesting completion of a survey from firms with Appointed Representatives (ARs). Where applicable, firms may already have received this. Given the risk of scams, the FCA now takes care to pre-warn firms that a communication is genuine. We have had confirmation that the following survey and email addresses used are legitimate. […]