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.



SM&CR – Conduct Rules reminder
Alistair MacDougall Compliance 2019, 2020, FCA, SM&CR
Firms need to undertake Conduct Rules training before 9 December 2019 for Senior Managers and Certification Staff.