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Insistent Clients: Identifying Them Then Dealing With Them And Remaining Compliant

fca conduct rules cobs insistent client sales process

fca conduct rules cobs insistent client sales process

What is an Insistent Client and how to deal with them.

The FCA Handbook does not refer to insistent clients and there are no rules or guidance specifically about this.

The following will hopefully help to show the FCA’s current stance after their recent consultation paper.

IMPORTANT!
Insistent Clients must not be confused with an Execution Only client

 

What Is Execution Only?
This is where the Client knows exactly what they want and the choices readily available incorporating the premium, sum assured, term and availability of critical illness, waiver, etc.

So What Is An Insistent Client?
This term is used to describe a situation where a client is adamant that they should be taking a different route of advice to that prescribed by the adviser.

This presentation contains images that were used under a Creative Commons License. Click here to see the full list of images and attributions: https://app.contentsamurai.com/cc/97859

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MIFID II What Compliance Wealth Managers & Advisers Need To Get In Place

MiFID II finally comes into effect on 3 January 2018

Although there may still be some grey areas, it is time to make sure you have your compliance arrangements in place or being progressed so that there are no nasty surprises.

Get a PDF of this post from this link (right click and “download as…”)

Here are 11 things we suggest wealth managers, asset managers or independent financial advisers do to best prepare themselves ahead of the New Year deadline:

1. Not only make a register of all conflicts of interest, but also articulate how these are mitigated or managed and review them, at least annually.

2. Review whether your firm needs additional qualifications, training or Part IV permissions to maintain independent status.

3. Structured Deposits: * HOTSPOT* Apply for new permissions by 2 January 2018 if you wish to advise on these.

4. Carefully consider your recruitment procedures and ascertain if they need tightening (consider SM&CR impacts too).

5. Conduct Risk: Review your remuneration structure and ensure no incentives negatively impact clients.

6. Decide which staff the “Personal Account Dealing” rule should apply to, and create a register of direct equities they hold.

7. Create or amend your Personal Account Dealing policy to reflect the need to report staff holdings changes.

8. Legal Entity Identifier: * HOTSPOT* Decide if you need to apply for this through the London Stock Exchange.

9. Confirm if your discretionary fund manager (DFM) or platform will offer online reporting access and thereby avoid the need for time consuming paper reporting.

10. Ensure you are comfortable with and confirm whether your DFM or platform will issue the 10% loss notification and how. This an extension of the COBS 16.3 rules (https://www.handbook.fca.org.uk/handbook/COBS/16/)

11. Check your agency agreement with your DFM where model portfolios are being used: does the responsibility for regular and ongoing checking of suitability sit with you as the adviser?

Legal Entity Identifier (LEI)
A key impact of the new regulations is that from 3 January 2018, an investment management firm will only be able to continue trading in financial markets on behalf of certain clients if those clients have obtained a LEI. If you have clients that are required to have an LEI, have you informed them of this? These entities include; Trusts (but not bare trusts), Companies (public and private), Pension Funds (but not selfinvested, personal pensions), Charities, and Unincorporated Bodies.

Note that investment trusts and ETFs are not excluded from the requirement for a LEI. Advisers might need to consider whether the cost of an LEI has any impact on a decision to use other than collectives in portfolios. The other point to note is that an LEI is NOT required if investment is being made exclusively in collectives such as investment bonds, OEICs or unit trusts.

How do you obtain an LEI?
The LEI can be obtained directly from the London Stock Exchange (LSE) for an initial fee of £115+VAT and there is an annual renewal fee of £70+VAT.

 

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What the FCA found when it did a Suitability Assessment of the IFA Sector in 2017

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incubator-nursery-fca-authorisation-startup

The Independent Financial Advice (IFA) sector was given a clean bill of health by the FCA in May 2017. Or was it?

A suitability review of 1,142 separate pieces of advice given by 656 firms against the rules in the Conduct of Business sourcebook showed that in 93.1% of cases, advice provided was suitable.

Interestingly enough, and one that the regulator has now agreed, they used a simple balance of probabilities of extrapolation of the data in their assessments, across the industry. This does not mean that the processes used to arrive at the suitable advice were correct, simply that the advice provided was more than likely to be what the client should have been recommended.

You have to dig your way through appendix 1 to find that 481 of the 656 firms in the sample had a single file examined. The file was chosen randomly, from advice given in 2015. We are pretty sure if an IFA told the FCA that its own quality assurance consisted of one file it would get a sudden amount of regulatory attention.

What, if any, assurance can consumers understand from this? Simply that in 2015, 481 firms of IFAs gave a single good piece of advice. The advice in 2013 could have been terrible and 2014 may not be described in any positive way.

So the next question must be; how is this reflected within the industry?

In January 2017, the Financial Services Compensation Scheme (FSCS) issued a statement, announcing three supplementary levies for 2016/17, totaling ₤114mn. Its Chief Executive explained:

” We will ask life and pensions intermediaries to pay their share of an additional ₤ 36m to fund compensation for the high numbers of SIPP-related claims we are continuing to receive, but also need to trigger a cross subsidy for the first time. These claims relate to advice to switch pension funds into high risk investments. We previously flagged the potential for high costs here … And we currently expect a deficit of ₤ 15m on our home finance intermediation account due largely to the failure of one particular firm that gave bad advice to engage in risky property investments alongside mortgage advice.”

The State of Play

The FCA says everything is fine. The FSCS says it needs more money due to poor advice surrounding self-invested pension plans, and pension transfers. In 2017 alone, the FSCS declared 90 firms in default. A lot of these were IFAs whose professional indemnity insurance claims limit were exhausted, and who couldn’t fund the Financial Ombudsman Service’s awards.

If you were running an IFA business, would you be telling everyone that the FCA are happy with ALL advisers and their suitable advice, or would you keep quiet in case someone digs deeper and finds the methodology was questionable?

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Suitability Definition, Suitability Assessment, Suitability Kyc, Suitability Rule Financial Advice

Corporate Financial Services Regulatory Compliance Enquiry Form

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Compliance Consultant is one of the UK’s leading FCA compliance consultancies. We help financial services firms achieve FCA & PRA Authorisation, Manage their Regulatory Obligations, Perform Compliance Audits and Past Business Reviews, SYSC Assessments and Empower their staff with bespoke and Direct Compliance Training.

Our compliance consultants are subject-matter experts and assist clients from a broad range of areas, these include, but are not limited to;

 

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The Myths Around Suitability Reports And How To Be A Hero

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A common misconception is that the suitability report has to ‘round up’ the whole process, discussions and background information that has occurred to date. It doesn’t. It simply forms part of the process of telling the story and, from a compliance perspective, will be read in conjunction with the rest of the data and information contained within the file.

This is good news. It means we can legitimately start taking ‘superfluous’ information out of the suitability report and make it shorter and more client-friendly.

Based on the regulators Principle 9 (customers: relationships of trust) “A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.”

In conjunction to that, and by extension, COBS 9.2.1 R states;

(1) A firm must take reasonable steps to ensure that a personal recommendation, or a decision to trade, is suitable for its client.
(2) When making the personal recommendation or managing his investments, the firm must obtain the necessary information regarding the client’s:
(a) knowledge and experience in the investment field relevant to the specific type of designated investment or service;
(b) financial situation; and
(c) investment objectives;

so as to enable the firm to make the recommendation, or take the decision, which is suitable for him.”

More recently, the Financial Ombudsman Service (FOS) has reiterated its advice to IFA’s to make suitability reports as tailored and personalised to the client as possible.

Richard Thompson, FOS principal ombudsman, speaking at the Money Marketing Interactive conference in May 2017, outlined how advisers should present a defence at the FOS when faced with a complaint. He said: “The more you can do to personalise and tailor that documentation, that suitability report around the customer and their circumstances, the better placed you will be to defend in the event that someone does wish to bring a complaint.”

fca-suitability-report-ifa-construction-guide1
Download Our Free Suitability Report Guide

While he admitted that “standard documentation always has its place” to help clarity or understanding for consumers, it also had its “limitations”.

Compliance Consultant has been championing the reduction of Suitability Report Length and rationalising the content to flow better and be more relevant. Founder and CEO of Compliance Consultant, Lee Werrell, said that

“Members of Networks and those using standardised ‘off-the-shelf’ compliance providers are given a bland, comprehensive and rigid suitability report template, based on the ancient ‘tied-agent’ model of command and control. This is so out of date in today’s relationship selling methodology that all the report does is take up the advisers time and contains mainly dross that used to be considered as ‘covering one’s backside’.”

Further to that, Werrell added “If you can explore and discuss the various elements of COBS9 with the client, and record their own words, you can replay it in the Suitability Report as further evidence of the client’s needs. From the fact find, file notes and through to the suitability report, there should be a flowing story; a story of demands, needs and satisfaction.”

At the conference, Thompson added that using the client’s own words in documentation was the “gold standard” when it came to best practice. He said: “It helps when we can see things in the advisers own words…The gold standard is the clients own words from what they understood then.” He also urged advisers to steer clear of jargon-heavy product information.

Compliance Consultant can conduct an audit of your firm and provide a comprehensive report setting out the work into the general areas which the FCA often express interest and which generate most concerns, incorporating the latest hotspots.

The scope of the work required by FCA visits, are, in our view, extensive and required to be delivered in a short space of time. Having all the evidence readily available, including ongoing action plans and risk identification is vital. The Compliance Consultant team is qualified to undertake this work has experience of working with many financial institutions and regulators, ranging from working at board level, senior management, line managers and directly supervising sales personnel.Call us on 020 3815 7939 for details, watch the video at https://youtu.be/z_hSI9tLCVI or go to http://wp.me/p7OMfd-vT.

An additional service we can provide is the relevant rules mapping from the FCA Handbook to your firm. Ask us for details, or go to the website via this link http://wp.me/p7OMfd-A2.

Compliance Consultant – “Making Compliance Work!” 

Call us on 020 3815 7939

IFAs! Have your work double-marked for suitability

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‘Can help iron out rough edges’

compliance-consultant-ifa-suitability-check-how to check suitability

Advisers should have their work checked over to make sure standards remain consistent and high, according to Threesixty Services managing director Phil Young.

 Small, independent and directly authorised firms performed slightly less consistently than their larger and restricted counterparts in the regulator’s recent suitability review, but Young argued even a peer-group review can help iron out the rough edges for smaller, independent firms.

“The bit I’m increasingly seeing over the years that has an impact on adviser behaviour is whether there’s an independent ‘second line’ of compliance review brought in,” he said.

Compliance Consultant have also noticed that there are poor standards and these often remain unchecked or reported. Until they get a visit!

We can Help – We can conduct a suitability review check for you at a reasonable cost. Don’t rely on your compliance outsourced service that just charge you a fee and spend a few hours with you each year.

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Source- https://www.professionaladviser.com/professional-adviser/news/3010804/have-your-work-double-marked-phil-young

2017 New Client Questionnaire – Compliance, Risk management & Governance

UK IFA Suitability Report Construction Guide

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Suitability Report Construction Guide

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