COBS 9 and COBS 9.4 are not the same rule

COBS 9 is the chapter on suitability. When a firm makes a personal recommendation, it must assess whether that recommendation is suitable for the client. That assessment looks at the client’s investment objectives, financial situation, knowledge and experience, risk tolerance, and capacity for loss.

COBS 9.4 is narrower. It sets out when a firm must give the client a suitability report, what the report must contain at a minimum, and when it must be provided. A report is required in the cases the Handbook lists (including certain fund and pension recommendations, income withdrawals, life policies, and pension transfers), and there are stated exceptions. We do not reproduce that list here.

For the rule text, use COBS 9.4 Suitability reports in the FCA Handbook. That page is the authority; this article is a high-level note for authors who already know the file.

What COBS 9.4 says the report must cover

Where a suitability report is required, COBS 9.4 says it must, at least:

  • specify the client’s demands and needs, from the information obtained;
  • explain why the firm concluded that the recommended transaction is suitable;
  • explain any possible disadvantages of the transaction for the client;
  • and, for a life policy, include a personalised recommendation explaining why that policy would best meet those demands and needs.

Timing and extra content (for example pension transfers) are also in COBS 9.4. If the file cannot show why this client, why this recommendation, the report has not done that job — that is a file test, not a software certificate.

Consumer Duty: understanding and value, not a new template

The Consumer Duty is about delivering good outcomes for retail customers. Its named outcomes include products and services, price and value, consumer understanding, and consumer support. A suitability report is one place the firm evidences understanding and value; it is not a substitute for the Duty as a whole.

Communications must be fair, clear and not misleading (COBS 4). A report that is complete on paper but opaque still fails the client. Headings and an indexed table of contents help a retail client navigate a long document. No format guarantees understanding.

What firms use the report for in practice

These are practice notes, not extra Handbook headings.

Personalised suitability

The rationale should link this client’s objectives and circumstances to the recommendation. Personalisation is the opposite of a template dump with names swapped in.

Consumer understanding

Plain English, a short summary before the detail, and a glossary where the file needs one, all help. Visuals and scenarios can help where the product is complex — they do not prove the client understood.

A record the firm can stand behind

A dated report, with a clear trail of what was considered, supports the firm’s own record-keeping and oversight. The report is evidence for the file. It is not a substitute for systems and controls, and software does not sign the advice off.

The wider advice journey

A useful report sits with the meeting, the recommendation, and later reviews: alternatives where they matter, vulnerability where it is relevant, and value. When circumstances change, the rationale on the file should change with them.

Something the client can return to

A clear report is a reference for the client and for the next review — not one-off paperwork to be filed and forgotten.

Structure, not a downloadable template

Searches for a “COBS report template” often want a Word file. The FCA does not mandate a single template. What matters is structure that can show suitability and support understanding: circumstances and demands and needs, recommendation and rationale, risk and capacity for loss, disadvantages and alternatives where relevant, and language the client can follow.

ProSuitability produces a structured first draft styled as a report with an indexed table of contents, so authors who already know what belongs in the file review instead of retype. Optional Virtual Paraplanner is a suggest-only Needs & Demands companion after the recommendation. It does not write Constructor fields or the suitability report.

How ProSuitability fits (and what it does not claim)

Fact-find and recommendation in; structured draft out; then adviser review and export. That is a drafting workflow. It does not certify advice, does not “make you compliant”, and does not replace the firm’s own standards.

What we do not claim: FCA approval of the product, ISO (or similar) certification, guaranteed suitable outcomes, or a fixed percentage time-save. The advice and the sign-off remain yours.

Related reading: Resources and AI suitability report software vs ChatGPT.