CONSUMER DUTY NEWSLETTER

16 CONSUMER DUTY NEWSLETTER A simple, well-laid out suitability report will not only document the advice to a client but also document all the alternative considerations an adviser has made. It will show why the advice is the best for the client. With Consumer Duty focused on client outcomes, the report becomes even more important to back up the advice a broker has given. It documents that the adviser has considered potential foreseeable harm, and it will show the client is aware of the cost of adding fees to a loan amongst other things. It is the document that summarises your advice; it doesn’t need to be long, but it must support the advice. We frequently work with firms to make sure their template meets the regulators requirements. An ‘Unclear’ grade is a fail. False. The FCA used to grade files as suitable, unclear or unsuitable. They have now changed to Suitable, Unsuitable (missing information) or Unsuitable (advice). At Paradigm, we have made a conscious decision not to adopt this approach. An 'unclear’ grade can be for a number of reasons, all of which we explain, however it is an opportunity for the adviser to add to the file and clarify the advice. Nine times out of ten, if the remedial action is followed, the advice will be suitable and be suitably documented. In the small amount of cases (mostly protection or investment advice) that are not suitable, we will then work with a firm to offer training, review documents and offer any support we can. The file review team at Paradigm are not a team that just tick boxes, they are not “business prevention”. There is no ‘one size fits all’ approach, and hence they do not review a file in that way. What they will do is work with your firm to understand your systems to help make sure the advice process is as robust as possible. The team can work both remotely or by going onsite to visit your business. More importantly, with Consumer Duty, they will work with advisers to ensure that the documentation of the advice is suitable. We pride ourselves on helping firms learn how to best protect their business, stay on Lender panels and off the FCA radar. All of the team have advised, and most have advised on mortgages, hence their support comes from experience and they understand there are many ways to evidence suitability. Firms will have the direct contact details of their file reviewer, and we encourage questions and discussion to develop a true business partnership. If you require further information on how our File Review team can help you to protect your business, please contact me on [email protected] .