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COBS Handbook - Step-by-Step Guide
The FCA's Conduct of Business Sourcebook is one of the most extensive rulebooks any regulated firm must navigate — governing everything from how you classify clients and assess suitability, to how you execute orders, handle inducements, disclose costs, and manage complaints. Get it wrong and you're not just facing regulatory censure — you're exposed to client redress, FOS referrals, and senior manager accountability under SM&CR. The FCA doesn't wait.
What's included:
Client classification framework: Retail, Professional, and Eligible Counterparty — including opt-up/opt-down procedures and ongoing review
Suitability and appropriateness assessments: knowledge and experience, financial situation, investment objectives, and execution-only services
Conflicts of interest and inducements: identification, management, permitted inducements, enhanced quality requirements, and disclosure
Best execution: execution policy requirements, order handling, asset class-specific rules, monitoring, and client reporting
Product governance: manufacturer and distributor obligations, target market determination, and ongoing monitoring
Record-keeping matrix: minimum retention periods, client file standards, audit trail requirements, and electronic systems
Complaints handling: acknowledgement timelines, investigation process, FOS interface, and redress obligations + much more
Who is this for?
Compliance Officers, SMF16 holders, Investment Advisers, and Governing Bodies at FCA-regulated investment firms who need a complete, board-approved COBS compliance framework ready to withstand FCA supervisory scrutiny.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
The FCA's Conduct of Business Sourcebook is one of the most extensive rulebooks any regulated firm must navigate — governing everything from how you classify clients and assess suitability, to how you execute orders, handle inducements, disclose costs, and manage complaints. Get it wrong and you're not just facing regulatory censure — you're exposed to client redress, FOS referrals, and senior manager accountability under SM&CR. The FCA doesn't wait.
What's included:
Client classification framework: Retail, Professional, and Eligible Counterparty — including opt-up/opt-down procedures and ongoing review
Suitability and appropriateness assessments: knowledge and experience, financial situation, investment objectives, and execution-only services
Conflicts of interest and inducements: identification, management, permitted inducements, enhanced quality requirements, and disclosure
Best execution: execution policy requirements, order handling, asset class-specific rules, monitoring, and client reporting
Product governance: manufacturer and distributor obligations, target market determination, and ongoing monitoring
Record-keeping matrix: minimum retention periods, client file standards, audit trail requirements, and electronic systems
Complaints handling: acknowledgement timelines, investigation process, FOS interface, and redress obligations + much more
Who is this for?
Compliance Officers, SMF16 holders, Investment Advisers, and Governing Bodies at FCA-regulated investment firms who need a complete, board-approved COBS compliance framework ready to withstand FCA supervisory scrutiny.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.

