7.1 Communication Skills for Advisers

Giving regulated financial advice is a communication-led activity. A technically perfect recommendation that the client does not understand, trust or act on is a failed advice interaction. The FCA's Principle 7 requires clear, fair and not misleading communications where that Principle applies. For activities within the Consumer Duty, Principle 12 and PRIN 2A instead require firms to deliver good outcomes, including a consumer-understanding outcome. Under PRIN 3.2.10R, Principle 7 does not separately apply to those same in-scope activities. Existing TCF guidance can still inform good communication practice.

The Four Communication Channels

Advisers communicate with clients through four overlapping channels. Weakness in any one undermines the others.

Oral Communication

Oral communication is live, two-way and immediate. An adviser must explain complex concepts (tax wrappers, annuity options, risk-reward trade-offs) in terms the client can use. Practical techniques include:

• Pacing: match the client's speed and vocabulary, not the adviser's jargon level.
• Signposting: tell the client what is coming next so they can process it ("I'll explain three options, then I'll ask what matters most to you").
• Recapping: summarise what was just said in the client's own words before moving on.
• Plain English: avoid acronyms and product codes; spell out FCA, ISA, CGT, ATR on first use.

Written Communication

Written communication is the evidential backbone of advice. COBS 9.4 requires a suitability report for personal recommendations, and the report must be clear, fair and not misleading. Common written documents an adviser produces include:

• Initial disclosure documents (services, costs, scope)
• Fact-find forms and risk-profile questionnaires
• Suitability reports and reasons-why documentation
• Key features illustrations and product disclosures
• Annual review statements (for ongoing services)

Written material must use plain English — short sentences, active voice, defined terms and a reading age accessible to the typical retail client. The FCA's existing TCF and Consumer Duty communications outcome both expect that a client can actually understand what they are being told, not merely receive it.

Listening Skills

Active listening is the deliberate practice of concentrating on what the client is saying rather than preparing the next question. Components include:

• Attending: eye contact, open posture, minimal encouragers ("mm-hm", "go on").
• Reflecting: paraphrase what was said ("So you want the mortgage paid off before you're 60, even if that means higher payments now?").
• Clarifying: ask the client to expand ("When you say 'safe', do you mean no risk of capital loss, or no risk of not meeting your goal?").
• Summarising: pull together threads before closing a topic.
• Tolerating silence: many clients need a few seconds to articulate financial worries.

Listening is also where an adviser detects vulnerability — hesitation, confusion, third-party pressure, or distress that signals the client may need additional support.

Questioning Skills

Skilful questioning moves a client from stated preferences ("I want a high-return investment") to actual objectives and constraints ("I need £40,000 for an extension in three years and cannot afford to lose capital"). Four main question types are used:

The funnel technique starts broad, narrows through probing questions, and finishes with closed questions that confirm understanding. It is the standard pattern for a fact-find interview.

Body Language and Non-Verbal Communication

Non-verbal cues reinforce or contradict spoken words. An adviser should:

• Maintain open body language and reasonable eye contact.
• Watch for mismatches (client says "I'm comfortable with risk" but shifts in seat and breaks eye contact) — these are signals to probe further.
• Be aware of their own non-verbal signals (impatience, ticking boxes without looking up) that may discourage the client from sharing.

Disclosing Scope of Service

Before advice is given, the client must understand what service they are getting. COBS 6.1 and the adviser charging rules require disclosure of:

• The type of service (independent, restricted, execution-only, basic advice).
• The scope of advice (which products, markets, providers).
• The charging structure (fee, commission where still permitted, ongoing service cost).
• Whether a personal recommendation will be made or merely information provided.

Mis-setting scope is a common cause of complaints: a client who expected a whole-of-market comparison but received a single-provider recommendation has grounds to complain, even if the recommendation itself was suitable.

Plain English and Accessible Formats

The FCA expects firms to make reasonable adjustments for clients with communication needs. Practical examples:

• Large-print or Braille documents for visually impaired clients.
• Translated materials or interpreter access where English is not the client's first language.
• Audio recordings of suitability reports for clients who struggle with written text.
• Extra time, plain-language explanations, and follow-up calls for clients with cognitive or literacy difficulties.

These are not optional courtesies — they are part of the Consumer Duty's requirement to enable clients to pursue their financial objectives.

Vulnerable Clients' Communication Needs

The FCA's FG21/1 guidance on the fair treatment of vulnerable customers (carried forward and strengthened under the Consumer Duty) sets out four drivers of vulnerability: health, life events, resilience and capability. A vulnerable client may have communication needs that require:

• Slower pacing and repetition of key points.
• Permission to involve a trusted third party (family member, advocate, interpreter).
• Shorter meetings or breaks to manage fatigue.
• Written summaries to reduce reliance on memory.
• Avoidance of jargon and complex product descriptions.

The adviser must record the indicators of vulnerability, the adjustments made, and any permission given to share information with a third party. A vulnerable client is still entitled to a suitable recommendation — the adjustment is to the communication, not the standard of advice.

Practical Communication Checklist

A skilled adviser treats communication as the product, not a wrapper around it. The Consumer Duty asks firms to evidence that clients understood their options and the recommendation — clear communication is how that evidence is generated.