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FinCom Bench

Sourcebooks / Disclosure

Disclosure

United Kingdom

UK — Disclosure

Source: FCA Handbook, COBS (Conduct of Business Sourcebook) chapter 6.

COBS 6.1.4R

Verbatim clause withheld — the publishing authority's reuse terms do not confirm a right to redistribute the exact text (see sourcebooks/NOTICE-SOURCEBOOKS.md). See the URL above for the original, and "What this means" below for Doshi's own paraphrase.

What this means. Before doing business, a firm must tell the client who it is: its name, address, and contact details. It must also state plainly that it is a firm authorised by the FCA or the PRA. Stating FCA or PRA authorisation is not just a formality — it is the fact that lets a client check the firm against the public Financial Services Register before trusting it with money.

COBS 6.1.11R

Verbatim clause withheld — the publishing authority's reuse terms do not confirm a right to redistribute the exact text (see sourcebooks/NOTICE-SOURCEBOOKS.md). See the URL above for the original, and "What this means" below for Doshi's own paraphrase.

What this means. A firm must give its disclosures to the client before the business starts, not after, except in narrow distance-sale cases. Even inside that exception, the firm is not excused from disclosing — only from disclosing first. The rule requires the firm to give the same information immediately after starting the business, not skip it.

European Union

EU — Disclosure

Source: PRIIPs Regulation (EU) No 1286/2014 and the Insurance Distribution Directive (EU) 2016/97, art. 20(5).

Note: fetched via legislation.gov.uk's EU-retained-law mirror, not eur-lex.europa.eu directly (eur-lex returned empty content on every attempt). See sourcebooks/suitability/eu.md for the full caveat.

PRIIPs Regulation art. 5(1)

Before a PRIIP is made available to retail investors, the PRIIP manufacturer shall draw up for that product a key information document in accordance with the requirements of this Regulation and shall publish the document on its website.

What this means. Before a packaged retail or insurance-based investment product (a PRIIP) is offered to retail investors, the firm that makes the product must write a Key Information Document for it and publish that document on its website. The investor should be able to read the key facts before they buy. The duty sits with the manufacturer, not the distributor — the firm selling the product to the investor is not the one required to write the Key Information Document, though separate rules require the distributor to hand it over before the sale completes.

IDD art. 20(5)

In relation to the distribution of non-life insurance products as listed in Annex I to Directive 2009/138/EC, the information referred to in paragraph 4 of this Article shall be provided by way of a standardised insurance product information document on paper or on another durable medium.

What this means. When a seller distributes a non-life insurance product, it must give the customer a standard-format insurance product information document. This can be on paper or another durable medium, and it must happen before the sale. The standard format is deliberate: every non-life insurance product in the EU uses the same document layout, so a customer comparing 2 insurers' car insurance can find the same information in the same place on both documents.

United States

US — Disclosure

Source: Regulation Best Interest, 17 CFR 240.15l-1 (disclosure sub-obligation, distinct from the best-interest clause already in rules/grading/product_recommendation.md), and the Form CRS delivery rule, 17 CFR 275.204-5. The Reg BI text was verified word for word against a second, independent fetch of the same Cornell Law page on 2026-08-12.

Reg BI 17 CFR 240.15l-1(a)(2)(i)

The broker, dealer, or natural person who is an associated person of a broker or dealer, prior to or at the time of the recommendation, provides the retail customer, in writing, full and fair disclosure of: (A) All material facts relating to the scope and terms of the relationship with the retail customer, including: (1) that the broker, dealer, or such natural person is acting as a broker, dealer, or an associated person of a broker or dealer with respect to the recommendation; (2) the material fees and costs that apply to the retail customer's transactions, holdings, and accounts; and (3) the type and scope of services provided to the retail customer, including any material limitations on the securities or investment strategies involving securities that may be recommended to the retail customer; and (B) all material facts relating to conflicts of interest that are associated with the recommendation.

What this means. Before or when it makes a recommendation, a broker must give the customer a written notice. The notice must cover fees, the scope of service, and conflicts of interest. This is 1 of Reg BI's 4 component obligations (see the best-interest clause already in rules/grading/product_recommendation.md) — a broker can satisfy the disclosure obligation in full and still fail Reg BI overall if it does not also meet the care, conflict-of-interest, and compliance obligations.

Form CRS 17 CFR 275.204-5(a)

If you are registered under the Act as an investment adviser, you must deliver Form CRS, required by Part 3 of Form ADV [17 CFR 279.1], to each retail investor.

What this means. A registered investment adviser must give a Form CRS relationship summary to each retail client. Form CRS states the adviser's services, fees, and conflicts in plain language. Form CRS and Reg BI's disclosure obligation above cover similar ground from 2 different regulatory angles — Form CRS applies to registered investment advisers, while Reg BI's disclosure duty applies to broker-dealers, so a dually registered firm has to satisfy both.

Australia

Australia — Disclosure

Source: ASIC RG 97 (disclosing fees and costs).

RG 97.2

The purpose of fees and costs disclosure is to ensure that consumers have accurate information to help their decision making. A consistent and transparent approach to fees and costs disclosure has benefits—for consumers, issuers and market professionals.

What this means. Fee disclosure exists to give the consumer accurate facts for a decision. A single, shared format for fee disclosure lets a consumer compare products fairly. The comparability goal is why RG 97 sets a fixed table format rather than letting each provider choose its own layout — a consumer comparing 2 superannuation products can line the same rows up side by side.

RG 97.36

You must include a 'Fees and costs summary' in a full PDS for superannuation products: see reg 7.9.16N(2)(a). The content is set out in cl 201 of Sch 10. It contains a table separated into 'Ongoing annual fees and costs' and 'Member activity related fees and costs'.

What this means. A superannuation Product Disclosure Statement must hold a fixed-format fee table. The table splits ongoing fees from fees tied to member actions. The split matters for how a member reads their total cost: an ongoing fee applies whether or not the member does anything, while an activity fee only appears in years the member switches investments, makes a withdrawal, or takes a similar action.