Many brokers use the FCA templates for disclosure, either the CIDD, IDD or both.  The FCA are concerned that the templates create a risk that firms adopt a tick-box approach to disclosure rather than creating a more personal form of disclosure to help your target customers understand the service you provide and costs. 

From a different viewpoint having a standardised template, as was the case prior to the MMR made it easier for consumers to compare service and cost levels between brokers. We havent come across any consumers which have had issues with the FCA format CIDD, its clear and easy to follow. The FCA however are looking to delete the IDD and CIDD templates from their website if the rules are made final, which will be in early 2016.  

You are free to comment on the planned changes as the consultation period will run up to the 18^th December.  

Once final you need to either create your own disclosure document or you can continue to use the FCA version layout but will need to remove the Key facts logo - not a great change then.  The FCA will allow reasonable time between the decision and the rules coming into force to use any old stock showing the keyfacts logo. 

The consultation paper can be viewed here: http://www.fca.org.uk/your-fca/documents/consultation-papers/cp15-32