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.



Principals and Appointed Representatives – action needed
Alistair MacDougall Compliance 2016, FCA, PI
Following recent FCA investigations that resulted in a Dear CEO letter, firms that have Appointed Representatives need to review the adequacy their governance and supervision.