There is a specific rule requirement to disclose any possible disadvantages in the suitability report. The rule (COBS 9.4.7) can be seen here: http://fshandbook.info/FS/html/FCA/COBS/9/4.
Remember that a disadvantage is different to a risk. For example, there is a risk that investments can fall in value, whereas a disadvantage would be that the recommended product has higher charges than the product being replaced.



Appointed Representatives and Introducers
Alistair MacDougall Compliance FCA
This FCA alert is of relevance to all Principal and Appointed Representative firms.