The FCA employs a principle based approach to regulation. Principle 7 states that “A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.”
This is a fundamental cornerstone required of all client communication.
While some degree of technical information is inevitable, your suitability reports should nevertheless be easily understood. One effective way to test the clarity of your suitability reports is to ask a friend or family member, who has no financial services experience, and who is more likely to provide frank observations, to read and to provide critical feedback.
Appointed Representatives – some SM&CR questions
John Begg Compliance 2018, Certification, Conduct, Directory, FCA, Register, Senior Manager, SM&CR
Occasionally, we come across firms that are ‘Principal Firms’ – i.e. the firm has Appointed Representatives (AR) but where one or more individuals straddle both the Principal and the AR. This can raise questions around the applicability of SM&CR to such individuals since the SM&CR does not apply to ARs. Why does the SM&CR not […]