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Discussion promptRegulation and Compliance

How much record keeping is proportionate?

Compliance CornerOfficial Contributor

Discussion prompts covering regulation, Consumer Duty, FCA developments and compliance.

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Suitability reports have grown steadily longer, and few advisers believe the extra length is read by clients. At the same time, thin files carry obvious risk if a recommendation is later questioned.

This matters because the point of the record is to demonstrate that advice was suitable and understood. Length is not the same as clarity, and a document written mainly for a future reviewer can fail the client it was written for.

Discussion questions:

  • How long are your suitability reports, and how have you tried to shorten them?
  • What have you removed without weakening the evidence trail?
  • Where does the client's understanding get lost in the documentation?

Firms should take their own compliance view; nothing here is regulatory guidance.

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