Why advice documentation is the new front line of compliance
The biggest risk often isn’t poor advice, it’s poor documentation. In the UK, defensibility depends on a clean chain from fact-finding to objectives, strategy and recommendation, with clear rationale and customer understanding evidenced for Consumer Duty. Weak files increase DISP exposure and undermine suitability (COBS). Shift from boilerplate to outcome-based file reviews, uplift documentation standards, and add AI guardrails (prompt discipline, audit trails, human verification) so “polished” outputs still reflect the client’s real intent.
How to apply in the UK
Standardise the evidence chain: Mandate auditable links and rationale in every suitability report; store to SYSC 9.
Risk-weighted QA: Use periodic sample-based file reviews to detect systemic gaps; prioritise remediation and training.
Clarity over volume: Measure client comprehension and fair value, not page count; remove boilerplate bloat.
AI with guardrails: Library of approved prompts, versioning and human sign-off before issuance.
