COBS 9B.7 When a firm is unable to provide a ready-made suggestion

1. (1) A firm may only deliver a ready-made suggestion to a client where it has identified that the client aligns with a consumer segment (COBS 9B.5.5R).

2. (2) This section sets out the steps which a firm should take where it is unable to provide a client with a ready-made suggestion.

    

Examples of reasons why a firm might be unable to provide a client with a ready-made suggestion include because the firm has:

1. (1) been unable to identify the client as being in a situation covered by a consumer segment;
2. (2) (where relevant) been unable to identify the client as having all of the including characteristics necessary to align the client with a consumer segment;
3. (3) (where relevant) identified that the client has an excluding characteristic which means that they cannot be aligned with a consumer segment;
4. (4) been unable to confirm that a client lacks all of the excluding characteristics necessary to align the client with a particular consumer segment; or

5. (5) identified or received additional information which means, or has led it to conclude, that it cannot provide a ready-made suggestion.

    

1. (1) In considering the appropriate course of action in relation to a client whom a firm has been unable to align with a consumer segment, a firm should have regard to its obligation to design and deliver support to retail customers (PRIN 2A.6.2R).
2. (2) Where a firm has been unable to provide a client with a ready-made suggestion, the firm should consider what alternative support, if any, it could usefully provide to that client. This may include directing the client to support (including investment advice) provided by other persons.

3. (3) Firms are reminded of their obligations under Principle 12 (Consumer Duty) and PRIN 2A – in particular, to act in good faith towards retail customers (PRIN 2A.2.1R) in a manner that is consistent with the reasonable expectations of those retail customers (PRIN 2A.2.2R).