Ange Lambert, a certified assessor who has marked over 250 Standard Set C assessments, spoke at the recent PAA roadshow about what and how much advisers need to do to satisfy the requirements of legislation.

And her message was that more is not always better when it comes to disclosure and other requirements around written documentation.

“The whole point of the regulations is to make advice more transparent and accessible to them [consumers]; keep it simple and relevant.”

Lambert said she had seen some “amazing fact-finders that are 10 to 15 pages long”; likely too long, she said, for clients to easily understand.

“You have to look at documents from a customer’s point of view; are you going overboard with the legislation?

“It can be very easy to go ‘I’ve got to put this and that in there’ and all of a sudden you’ve got two or three pages of disclaimers in the statements.”

She also told advisers: “Don’t be scared to tailor the documents to your business; the types of advice you’re giving and the types of clients you have.

The important thing is having a consistent process and sticking to it even though the documents may change.” Advisers should look for ways to reduce as opposed to increase their paperwork, such as by eliminating unnecessary duplication of documents, Lambert said.

For instance, she said some advisers were getting clients to sign essentially the same disclosure statement twice when they only needed evidence of it once.

She also warned insurance advisers to make sure they separately saved each version of policy documents, in case clients tried to make a complaint based on the current wording which had been changed.