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 expectations – temporary long term absence
Richard Foster Compliance 2020, 2021, Certification, Conduct, Directory, FCA, PI, Register, Senior Manager, transfer
Following consultation in CP20/23, which was published in December 2020, the FCA has made changes to the Handbook. The affected sections are: SYSC 25.4 FIT 1.3 SUP 10A.14, 10C.9, 10C.10, 10C.11, 10C.14, 10C Annex 2G and 10C Annex 6R Form D In summary, the changes to the Handbook are intended to reflect the FCA’s […]