The Charity Commission’s revised CC14 guidance places too much responsibility on trustees, CFDG has argued.

In its consultation response, the finance directors’ body said some trustees, particularly those without investment knowledge or experience, “may find the guidance overwhelming’, highlighting that they are now required to set the policy statement, assess the ability of an investment manager and judge their performance.

CFDG also addresses a passage in the draft guidance which stipulates that “a trustee who has some specialist knowledge…is expected to use it when acting as a trustee”.

The umbrella body argues that while it is understandable that trustees with more professional knowledge will be expected to use it, and indeed are often selected for this expertise, decisions should be collective.

Meanwhile, CFDG says that while the guidance is generally clear and easy to understand, there is a need for added bullet points, summary lists and tables.

It also points out that some areas may become out-of-date “very quickly” due to changes in the investment landscape.