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One of the biggest difficulties ensuring that your CIP is compliant is making sure that it is genuinely independent. Recent feedback from advisers who have been discussing their CIP with the FCA has reinforced the importance of this.

However, this can be a problem when outsourcing: you loose an element of independence when you hand your clients over to a DFM or risk ‘shoehorning’ them into a managed fund solution that isn’t appropriate for them.