In its response to the said “all rules are created equal” and supported the watchdog's suggestion that it develop an indication of priority in a ‘layering’ approach.

“We believe it is the broader regulatory environment, including the huge number of rules, combined with fear of how complaints are assessed by the Ombudsman that gives rise to the lengthy paperwork clients receive,” said APFA's director general, Chris Hannant.

“We look forward to working with the FCA, the advice community and others to improve consumer communications especially in terms of developing the FCA’s layering concept and how this may apply to suitability reports. However, to encourage advisOrs in practice to adopt new practices, it is important that they have confidence in the approach of the Financial Ombudsman in assessing complaints.”