Sub-benchmark fund performance over a set number of quarters could serve as a TCF assessment trigger, JPMorgan has claimed.
In a treating customers fairly report from the group, it suggests advisers should set targets for TCF outcomes, record the level reached and define the action taken if targets are not met.
Under its proposals, advisers would inform clients of this underperformance and suggest alternative products, as well as interrogate the provider on the reason for the downturn.
JPM said this meets the FSA's TCF outcome five, which requires consumers to be provided with products that perform as firms have led them to expect.
Other suggested benchmarks centre on products cancelled for suitability reasons, putting limits on the amount per adviser and per provider in a single quarter.
If breached, the group suggests firms should review an individual's sales process and offer further training where necessary.
Elsewhere, JPM research found reasonable clear charges are the most persuasive factor in getting clients to use advisers.
According to the survey, the two most popular charging methods are a one-off upfront fee paid by the customer and some manner of performance-related system.
A quarter of investors favoured each of these, compared with just 15% highlighting commission and 8% fees.
Head of UK retail sales at JPM Jasper Berens said this preference for commission over fee is essentially at odds with their desire for impartiality of advice.
"What it does suggest however is that consumers do not favour open-ended charging structures with no link to the results an adviser is achieving on their behalf," he added.
"The potential issues and obstacles surrounding performance-based remuneration are extensive. Nonetheless, remuneration linked to the investment performance achieved for clients may sit well with the outcome-based thinking encouraged by the TCF regime and is well worth exploring."
