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.



Questions, questions…
Paul Jay Compliance 2023, FCA, Periodic Review, PI, platform, training, vulnerable, Xplan
As a result of firms needing to implement Consumer Duty this year (and many still don’t appear to have their act together yet), there hasn’t been much output from the regulator in the latter half of 2023. That has changed. In recent weeks the FCA seems to have issued more paper than confetti at a […]