Presentation on theme: "Best Practice Forums November/ December 2013. Agenda for today…. Paradigm Compliance Update Fidelity Post Financial Crises World Skandia Rebate & Legacy."— Presentation transcript:
Best Practice Forums November/ December 2013
Agenda for today…. Paradigm Compliance Update Fidelity Post Financial Crises World Skandia Rebate & Legacy issues for Platform Business Threedneedle Active Investing Coffee Break J P Morgan The Only Market Update you will ever need Smith & Williamson Investment Trusts Blackrock Getting Active about Passive Paradigm Practical exercises looking at File Keeping Lunch
Graeme Stewart Compliance Partner
You Told Us…. (Thank you) You wanted more Compliance and more practical Compliance You Loved the format You Loved the RIP topics and Market Updates More than 1 in 3 gave 5/5 for quality and 5/5 for value 165 attended (164 said they would come back)
Your CPD Short sharp bursts of CPD for you to follow up All material and slides you see today are on our Website
Compliance Update We have Changed Post RDR T & C and file review standards Post RDR risk / fund / portfolio switches Post RDR audit and audit of on-going services Brief Look at; Consumer Credit Thematic Review Outcomes UCIS BRAW The 6 Killer Answers
The New Look Target
The New Look Website
Post RDR File Review Standards Chapter 3 A New Fact Finds (more soft fact prompts) New File Review Standards Chapter 7 New T & C Key Performance Indicators (MI for your Business)
T & C Changes we have made to help you Pre - RDR T&C KPI Benchmarks Provider Spread Product Spread NTU/ NPW Persistency Post – RDR T&C KPI Benchmarks Annual review / ongoing service Model portfolio fund switching Service propositions WRAP Adviser charging by facilitation
Post RDR T & C changes Annual review / ongoing service No more than X% (e.g. 5) of clients have not responded to a fund switching request Service propositions No more than X% (e.g. 20) of clients have taken proposition 1,2,3, etc. or transactional
Post RDR T & C changes WRAP No client with less than £50,000 to invest has been placed into a WRAP with prior approval Adviser charging by facilitation No more than X% (e.g. 10) of cases have been remuneration via product facilitation
Post RDR risk / fund / portfolio switches Chapter 6 Appendix 15 – Risk Plan Chapter 3 Appendix 18 – Fund switching guidance Appendix 19 – Portfolio switching guidance
Post RDR audit and audit of on-going services End of Year Review We will Help you audit your on-going advice proposition delivery (Chapter 6 appendix 16) RDR Audit kit Target August 2013
CPD Sources FT adviser, adviser hub New Model Adviser Academy Skills serve (Gavin Pilford ) ETF, VCT, EIS, BPR Ingenious/ Octopus Tax Efficient Review – Investment Trusts ~ JP Morgan / UCIS/ SCARPS ~ Paradigm Academy –
Other Updates UCIS New chapter 3D Thematic Review Anti Money Laundering and Anti Bribery and Corruption Systems and Controls New Guidance Consumer Credit Licence AR firms will need to apply for interim permission which will then be cancelled (for no charge) when authorised firm has permissions
The 6 Killer Answers 1.Do your (and all adviser in practice) CPD records show that you are able, willing and demonstrable competent to advise on the 8 RIP’s, National Savings and Cash ISA investments?
The 6 Killer Answers 2. Do your Client files show to a third party unbiased and unrestricted research and discount the relevant RIP’s
The 6 Killer Answers 3. Does you firm have evidence of the training provided to advisers in the using you post RDR Disclosure Documents?
The 6 Killer Answers 4. Can your firm evidence how you deliver the on- going service each client has been promised?
The 6 Killer Answers 5. Did you adapt your client agreement following the guidance in Target?
The 6 Killer Answers 6. Are you ready for BRAW? (if completed BRAW, have you now fully debriefed)
Compliance Update Thank You We are here to help you Have a great day …. See you a bit later
Best Practice Forums November/ December 2013
The Green Pathway – Reminder Main Reasons why files fail FCA expectations; Insufficient KYC Information (Hard and Soft Facts) Product Fully Explained Risk Attitude Discussed and Matched Replacement Business
The Green Pathway – Reminder Main Reasons why files fail FCA expectations; Insufficient KYC Information (Hard and Soft Facts) Client objectives/ goals/ aims/ aspirations/ timeframes/ purpose of income required/ knowledge and experiences ….so that it is clear to a third party…..(a story please)
The Green Pathway – Reminder Main Reasons why file fail FCA expectations; Product Fully Explained How the client needs are met by how the product works ~ I have selected this product for you because…
The Green Pathway – Reminder Main Reasons why file fail FCA expectations; Risk Attitude Discussed and Matched What discussion took place around ATR/ Capacity for Loss/ did the client agree with the risk profile outcome? And why
The Green Pathway – Reminder What have we been doing to help you? Updated File Review Checklists Updated Fact Finds in August 2013 Little exercise for you today
File Review; Best Practice Practical Exercise: Daniels Case Study Please take 10 minutes to read the Fact Find I am distributing
File Review; Best Practice Good Points; Well Completed Fully Completed No gaps No typos Easy on the eye Pretty good hard and soft facts
File Review; Best Practice Bad points; Insufficient details about client needs in order to make a recommendation….. Look at the supplementary questionnaire……..
File Review; Best Practice Do we have enough detail now to give advice? Please review selection of Suitability Report
MetLife Presentation (Partner Forums, Sept 2013) Lack of Information to demonstrate Suitability Insufficient or incorrect disclosure documentation Insufficient or missing client objectives Insufficient evidence to show why TFC and / or Income is required Insufficient evidence to show why the amount of TFC and / or income is required Insufficient evidence to show how client ATR / CFL has been arrived at
File Review; Best Practice PPOL (or A. N. Other electronic system) Excellent to explain products (PPOL use appendices) Excellent for laying out a letter Poor for highlighting soft facts Poor in generating specific reasons why Poor at discounting options and other potentially suitable products
Thank you for coming Has that been helpful? Please leave your feedback sheets on your table for collection We wish you a safe journey home