FSA's IDD and menu templates mislead firms

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The FSA's templates for initial disclosure documents (IDD) and menus have a higher number of non-compliance problems among firms that use them compared to those who create their own versions.

An FSA review of its implementation of COBS, found firms that created their own IDD and menu without using the FSA's recommended templates produce better documentation than those who use the COBS guidance. The FSA also says it remains concerned a large number of firms only had a basic understanding of COBS months after it came into effect. COBS guidance, published in November 2007, contained a number of templates for firms to use when constructing their IDD and menu. However, the FSA found a high proportion were failing to comply in a number of areas, including missing information on ...

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