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.



Papers galore!
Huw Reynolds Compliance 2021, Certification, Conduct, COVID-19, FCA, Gabriel, Pension, platform, protection, Senior Manager, SM&CR, Switch, transfer
It has been a busy month for papers and publications at the FCA. These include: New Consumer Duty CP The FCA is consulting on plans to introduce a new Consumer Duty, which aims to set a higher level of consumer protection in retail financial markets. The Duty will have 3 key elements: A new Principle – the […]