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.
Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.
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New disclosure rules that were intended to take effect from January 2017 have been put back one year.
Does your firm have sufficiently robust systems and controls, policies and procedures and governance in place to mitigate financial crime?
Are you completing your RMAR correctly?
If you have clients with overseas income or assets you might need to notify them of HMRC requirements.
P2P permissions – action required by 31 December 2016
Alistair MacDougall Compliance 2016
If you do not advise on P2P agreements, you need to consider whether you should remove this permission.