Suitability crackdown gathers pace as FSA issues 166s in wake of Dear CEO letter

Robert Hupe, a compliance consultant at investment regulation service provider Knadel, said that firms he works with typically highlight reporting as a weak spot.

He said: ‘The FSA will normally have concerns about documentation and demonstrating repeatability of processes across client portfolios and that the company management have clear reporting lines to ensure client outcomes are repeatable.’

The Association of Private Client Investment Managers has previously said its members are concerned Skilled Persons reports were no longer reserved for high risk operations.

‘Section 166s appear sadly to have become a way of life across the industry as a tool used by regulators. This not only increases costs to firms, but it is typically a cost that has not been budgeted,’ a spokesperson said.