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.
Double bubble equals trouble
Paul Jay Compliance EBI, FCA, PI, platform
A lot of our recent articles have provided our views on what we see as a significant shift in the FCA’s stance and the tone of their language. Not because we do so for the fun of it, but because there has been a tangible shift. As yet, the anticipated findings from the thematic review […]