Are you aware of ASR2?
not then you need to get with the FCA TLA’s!
Assessing Suitability Review 2.
This is the second stage of the FCA’s plan to assess suitability across the IFA market in investments and pensions. It will take place later this year – and your firm could be selected for the review. The review will ask for your new biz book. It will then pick files to check, and you’ll be sending in the FF and SR plus supporting documentation for FCA to check. If your firm are deemed below average then you will be asked to account for it.
In the 2017 review
58% of files in small independent firms were deemed to have submitted unacceptable disclosure (31% in networks) to their customers.(section 4.6)
You need to make sure you don’t land on that part of the next FCA Venn diagram. Get your files checked by IFAC.