Suitability reports are time consuming to write, time consuming to read, involve a lot of repetition and are viewed with suspicion by regulators, ombudsmen, compliance and customers. â€œThe best is the enemy of the goodâ€ advisers cry as they try and fit yet more mandatory items into SR reports.
Regulators equally cry that these are reports are unnecessarily long. Luckily for the compliance industry that IFAC represent, the FCA never once say exactly what they do want, or how they propose these reports should be shortened.
Weirdly the FCA rules have little to say about Suitability reports. Even what they do say can be condensed to explaining why you recommended it, and what the disadvantages are. See Cobs 9 for yourself. If taken at face value youâ€™d be amazed what falls off the back of what looks easy. Admittedly there are added requirements for income drawdown and Pension Transfers, but the aim of the SR is to ensure and that the product advice is accurate and achieves its purpose. What is currently acceptable and not acceptable in SR reports is given in various policy papers and is a subjective judgement made by FCA, FOS and compliance file checking. There is no silver bullet, and, as we often say, if it was easy, monkeys and machines would be doing your job.
That said, you can simplify things. IFAC have one way that is simple and effective, and avoids re-keying information. Attach the FF to the back of the SR report. Where the customer â€œdid not wish to discussâ€ then scrawl that all over the relevant section for the customer to see and mark your advice as limited or restricted, rather than holistic. Make sure the FF is up to date and dated, freeze your copy for posterity, and send it on.
One of the most common questions asked is "should the customer sign it?" and the answer here is also ambivalent - IFAC do not believe that adds much value. But sending it with the SR report? Yes, that is key. If you attach the fact find, then the SR report is invariably shortened, with a reference to reading the attached. â€œSee attached fact find, please let me know if there ae any errors recorded there.â€
At present IFAC are embarked on a major project to upgrade the auto SR letters for you to use inside BAT. Where previously a summary was used to explain the background to the case, now a fact find can replace that. Where the FF contains notes and soft facts, all the better to support your case later on if challenged. Go on - I dare you, save yourself time.
Product transfer is now in the auto-SR suite of docs
Mortgage SR â€“ all types â€“ is now in the auto SR suite of docs.