August 2017 Offer

We all know that the summer months can be quiet for IFAs and what better time to get those awkward jobs dealt with?

At Compliance Consultant we also know that whether you are independent or restricted, there are a number of issues that need addressing.

“We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure …….. further work is required by the sector”

The FCA stated in their report on “Suitability” in May  that “We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure and further work is required by the sector to improve the initial disclosure (includes firm’s costs and services).”

Having met with the FCA Supervision Team (authors of the report) recently we have a good handle on what they mean and what they hoped to see already in place.

Additionally there was also a great deal of discussion around the suitability letter construction and what content should be included.

Regarding the Senior Managers & Certification Regime, ( we have already worked on this for banking groups and know what is involved, the final tweaks are awaited but

In the details released on 26th July 2017, the FCA said the requirements will include “responsibilities maps, handover procedures, and will need to make sure that there is a senior manager responsible for every area of their firm”.

This means that your procedures need to be identified, mapped and recorded with owners and relevant controls.

What We Are Offering

To Help You Ensure You Are Comfortable With Your Compliance Affairs, We Have Two Offers;

5 Days Work for the price of 4

If you have a piece of work that needs doing, we will arrange to provide 5 days service either at your work site or from a distance (typically report writing etc) at a 20% Discount if at least 5 days work is booked.

What Does This Mean?

This means simply whereby we would normally charge in the range of £650 to £850 for a days’ consultancy work, over a week that would be £3,250 to £4,250 – with our offer that is reduced to £2,600 to £3,400 and no VAT!

As An Extra

We Operate A “Benchmarking Audit” and that is on special offer until 4th August from £2,600 discounted to £2,080 with no VAT!

We can offer these discount ONLY FOR WORK BOOKED IN BY

5.00pm 4th AUGUST 2017

CLICK HERE to register your interest and get a copy of our

“Suitability Guide” absolutely Free!

Don’t want the guide? Need to talk to us straight away? Call 0203 815 7939 now!


The Myths Around Suitability Reports And How To Be A Hero


A common misconception is that the suitability report has to ‘round up’ the whole process, discussions and background information that has occurred to date. It doesn’t. It simply forms part of the process of telling the story and, from a compliance perspective, will be read in conjunction with the rest of the data and information contained within the file.

This is good news. It means we can legitimately start taking ‘superfluous’ information out of the suitability report and make it shorter and more client-friendly.

Based on the regulators Principle 9 (customers: relationships of trust) “A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.”

In conjunction to that, and by extension, COBS 9.2.1 R states;

(1) A firm must take reasonable steps to ensure that a personal recommendation, or a decision to trade, is suitable for its client.
(2) When making the personal recommendation or managing his investments, the firm must obtain the necessary information regarding the client’s:
(a) knowledge and experience in the investment field relevant to the specific type of designated investment or service;
(b) financial situation; and
(c) investment objectives;

so as to enable the firm to make the recommendation, or take the decision, which is suitable for him.”

More recently, the Financial Ombudsman Service (FOS) has reiterated its advice to IFA’s to make suitability reports as tailored and personalised to the client as possible.

Richard Thompson, FOS principal ombudsman, speaking at the Money Marketing Interactive conference in May 2017, outlined how advisers should present a defence at the FOS when faced with a complaint. He said: “The more you can do to personalise and tailor that documentation, that suitability report around the customer and their circumstances, the better placed you will be to defend in the event that someone does wish to bring a complaint.”

                      Download Our Free Suitability Report Guide

While he admitted that “standard documentation always has its place” to help clarity or understanding for consumers, it also had its “limitations”.

Compliance Consultant has been championing the reduction of Suitability Report Length and rationalising the content to flow better and be more relevant. Founder and CEO of Compliance Consultant, Lee Werrell, said that

“Members of Networks and those using standardised ‘off-the-shelf’ compliance providers are given a bland, comprehensive and rigid suitability report template, based on the ancient ‘tied-agent’ model of command and control. This is so out of date in today’s relationship selling methodology that all the report does is take up the advisers time and contains mainly dross that used to be considered as ‘covering one’s backside’.”

Further to that, Werrell added “If you can explore and discuss the various elements of COBS9 with the client, and record their own words, you can replay it in the Suitability Report as further evidence of the client’s needs. From the fact find, file notes and through to the suitability report, there should be a flowing story; a story of demands, needs and satisfaction.”

At the conference, Thompson added that using the client’s own words in documentation was the “gold standard” when it came to best practice. He said: “It helps when we can see things in the advisers own words…The gold standard is the clients own words from what they understood then.” He also urged advisers to steer clear of jargon-heavy product information.

Compliance Consultant can conduct an audit of your firm and provide a comprehensive report setting out the work into the general areas which the FCA often express interest and which generate most concerns, incorporating the latest hotspots.

The scope of the work required by FCA visits, are, in our view, extensive and required to be delivered in a short space of time. Having all the evidence readily available, including ongoing action plans and risk identification is vital. The Compliance Consultant team is qualified to undertake this work has experience of working with many financial institutions and regulators, ranging from working at board level, senior management, line managers and directly supervising sales personnel.Call us on 020 3815 7939 for details, watch the video at or go to

An additional service we can provide is the relevant rules mapping from the FCA Handbook to your firm. Ask us for details, or go to the website via this link

Compliance Consultant – “Making Compliance Work!” 

Call us on 020 3815 7939

2017 New Client Questionnaire – Compliance, Risk management & Governance

FCA tells firms to revisit past advice after suitability review

FCA tells firms to revisit past advice after suitability review

The Financial Conduct Authority (FCA) has said firms should revisit advice given in the past after it found unacceptable examples of suitability reports as part of a review which involved 700 firms.

In April 2016 the FCA started the review when it asked firms for suitability reports from the previous year.

The regulator has recently begun to send out letters to firms which took part in the review, detailing what it found out about individual firms.

As well as looking at suitability requirements for a particular client, the regulator has commented on whether reports have met disclosure rules and looked for ‘indications of weaknesses’ in the advice process.

Firms which did not meet the regulator’s standards have been told to rethink advice given in the past.

‘Where we have identified issues with your advice process, please consider how these may have affected any clients and what actions need to be taken to improve these processes going forward,’ the letter, seen by New Model Adviser®, said.

‘Where applicable, you should look to revisit any advice that may need reconsideration and possible further action by your firm.’

In the letter, the FCA tells firms whether the suitability report showed the advice was suitable, unsuitable or unclear. It also tells firms if the level of disclosure is acceptable, unclear or unacceptable.

Problems with advice processes are also identified, where the regulator looked to identify problems which may affect other clients not included in the review.

The FCA said that where problems have been identified with a suitability report, advice firms should tell the clients about any missing information.

‘Please revisit the client file and consider how the client can be informed of the necessary information that has been omitted. In addition, consider how the omission of relevant information disclosure might have adversely impacted other clients and consider whether this omission reveals an area in your wider advice process which might be improved,’ it said.

Advice firms have two weeks to contest any inaccuracies in the FCA’s response.

Public findings?

The FCA has so far stopped short of publishing wider findings from the review of suitability reports.

However, under the ‘next steps’ heading in the letter the regulator said it was considering how to publish general findings from the reports to investment advisers.

‘The findings in this letter are specific to your firm and do not constitute general findings from our review. We will not name firms when communicating any general findings,’ it said.

Compliance Consultant can provide past business review services for any size of IFA or Wealth Manager. Please contact our London office on

0203 815 7939 or 0207 097 1434

regulatory,compliance,specialist,consultancy,requirements notice,s166