The Association of Professional Financial Advisers (APFA) has published a guidance paper for financial advisers to help them understand the FCA’s expectations and views on what constitutes best practice when trying to produce clear, concise suitability reports for clients.
The paper comes after APFA held discussions with the FCA, the FOS and others in the wake of the FCA’s Smarter Consumer Communications work, which looked at how financial services firms could communicate information to consumers in a clearer way which encourages consumers to engage with their financial decisions.
One key concept highlighted by the FCA’s work was that of ‘layering’ of suitability reports, where the most important information is placed or summarised at the beginning of the report.
The guidance brings together some of the existing FCA guidance on suitability reports and also updates members on current FCA thinking on some of the key issues and questions that advisers have about what should and should not be in a suitability report. The paper covers both content and formatting and also provides further information regarding how the FCA’s layering approach might be applied in practice by advisers.
Caroline Escott, APFA senior policy adviser, says: “We welcomed the work that the FCA has been doing on smarter communications for consumers. It’s clear that producing piles of paperwork that never gets read does little to encourage clients to engage with their financial decisions.
“The FCA has often said that it is possible to produce short suitability reports which still manage to communicate all the relevant information. Advisers told us they felt frustrated at the lack of specific guidance from the FCA in this area, which is why we decided to try to fill that gap with our guide.
“We still believe that there is more the government and regulator could do to encourage advisers to produce more concise suitability reports. One such step could be to prune the number of different rules and regulations covering disclosure, although we recognise that many of these requirements come from European directives and regulations. However, the industry must also play its part and we are grateful to members, as well as to the FCA and FOS, for working with us extensively on this issue. We hope that our paper, which draws on these discussions, will make it clearer for advisers exactly what the FCA believes is best practice in this area and help them produce shorter, clearer suitability reports for clients.”
