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.



Model behaviour
Alistair MacDougall Compliance Drawdown, EBI, FCA, ML, PI, Switch
The advent of Consumer Duty has catalysed a lot of focus on fair value, or at least a lot of chat. Anecdotal evidence would appear to suggest that many firms may not have made any material changes to their charging structures. However, a recent survey by Schroders gave rise to a headline in the financial […]