# Suitability report file check: the COBS 9.4.7R minimum, the Consumer Duty points and the timing rule for the product, as a pass or fail table > Pick the recommendation type and answer twelve yes or no questions to test a suitability report against COBS 9.4.7R, the Consumer Duty and the timing rule. - Page to cite: https://aeolookup.com/financial-advisers/suitability-report-file-check-cobs-9-4-7/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Financial advisers and mortgage brokers, Suitability reports and files - Published 1 October 2026 - Key fact: COBS 9.4.7R sets three minimum contents for a suitability report, the client's demands and needs, why the firm concluded the recommendation is suitable on the client's information, and any possible disadvantages, and the timing rule in COBS 9.4.4R differs by product: within 14 days of the contract for a pension, in good time before the transaction for a pension transfer, before the contract for a life policy. - Sources: FCA Handbook COBS 9.4.1R (when required), 9.4.4R (timing), 9.4.7R (contents), read 2026-10-01; COBS 6.1ZA and 6.1A (costs and charges; adviser charging); PRIN 2A (Consumer Duty); FG21/1 (vulnerability); CP26/10, 25 March 2026 (reports to carry only useful, relevant information); MCOB 4.7A for mortgages. Tested in headless Edge 2026-10-01. "Suitability report template" and "what is a suitability report" are the two most-typed report searches in the sector, and most of what answers them is either a vendor's template or a definition. This check is neither. It is the twelve questions a file reviewer asks of a draft, with the three that decide whether it is a suitability report at all kept separate from the nine that decide whether it is a good one. **Free tool on the page:** Suitability report file check: the COBS 9.4.7R minimum, the Consumer Duty points and the timing rule for the product, as a pass or fail table. It runs in the browser at https://aeolookup.com/financial-advisers/suitability-report-file-check-cobs-9-4-7/#tool and asks for no sign-up. ## The three that make it a suitability report COBS 9.4.7R says the report must, as a minimum, specify the client's demands and needs on the basis of the information obtained from the client; explain why the firm has concluded that the recommended transaction is suitable for the client having regard to that information; and explain any possible disadvantages of the transaction for the client. A draft missing any of the three goes back to the drafter. The adviser should not be reading it yet, because the adviser's time is for the judgement, not the structure. The third is the one most often missing. Reports that are long on reasons to proceed and silent on what the client gives up are the "too much information rather than too little" that the trade press describes, and the Consumer Duty's understanding outcome is the rule that now bites on them. ## The nine that make it a good one Costs and charges in pounds and percent with their cumulative effect (the MiFID II disclosure, and the [charging illustration](https://aeolookup.com/financial-advisers/adviser-charging-illustration-calculator-cumulative-effect/) produces the table); attitude to risk and capacity for loss recorded and matched to the recommendation; alternatives considered, including the existing arrangement and doing nothing; the ongoing service described with its cost and how to cancel; vulnerability considered and recorded; written for the client, in plain English, with the recommendation near the front; fair value considered; delivered within the timing rule; and the adviser's signature. The check is of presence. Whether the reasons are good reasons, whether the risk match is right, whether the alternatives were fairly weighed: those are the adviser's judgement and the compliance function's review, and no checklist replaces them. ## The timing rule changes by product COBS 9.4.4R: for a life policy, before the contract is concluded; for a pension scheme, within 14 days of the contract; for a pension transfer or conversion, in good time before the transaction is effected; otherwise when the recommendation is made or as soon as possible after the transaction. The check prints the rule for the product selected, because the pension transfer case is the one that gets the order wrong: the report is the thing the client reads before deciding, not a record made afterwards. For a mortgage, MCOB 4.7A applies instead. There is no suitability report in the COBS sense, but the file records why the mortgage is suitable, and the check says so rather than inventing a requirement. ## Where CP26/10 is heading The FCA's March 2026 consultation proposes consolidating the timing and content requirements and requiring that reports include only useful, relevant information for the client, with layering of disclosures and risk warnings. The direction is shorter reports built around the three minimum items. A firm that passes this check today is already most of the way to what the policy statement will ask for. ## In the firm An AI Report Drafter set up by Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) drafts the report on the firm's own template from the fact-find and the adviser's notes, and an AI File Checker from the same set-up runs this check on every draft before the adviser sees it, listing what is missing by rule reference. The adviser reviews, amends and signs; the compliance function reviews on the firm's sampling basis. The drafter never decides what is suitable and never sends a report to a client. The [letter of authority chaser](https://aeolookup.com/financial-advisers/letter-of-authority-chase-email-template-adviser/) collects the plan information the report depends on. Not regulatory advice. ## Short answers from this page **What must a suitability report contain?** As a minimum, three things: the client's demands and needs, why the firm concluded the recommendation is suitable having regard to the information the client gave, and any possible disadvantages of the transaction for the client. A document missing any of the three is not a suitability report under the rule. **When must a suitability report be given to the client?** It depends on the product. For a life policy, before the contract is concluded. For a pension scheme, within 14 days of the contract. For a pension transfer or conversion, in good time before the transaction is effected. Otherwise, when the recommendation is made or as soon as possible after the transaction. --- ![](https://aeolookup.com/img/d/owner-line.png) General information for UK small firms, not legal, tax or financial advice.