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.



Regulatory permission – use it or lose it
Michael Senior Compliance 2021, FCA, ML, protection, Register
The FCA has published draft guidance on a new power that allows it to move faster to remove regulatory permissions that are no longer being used by financial services firms. Responses to the consultation (CP21/28) close on 29 October 2021. The driver behind the proposed power is the regulator’s belief that incorrect or outdated permissions […]