The tentative question posed in the heading to this article refers to the vagueness of the rules around when disclosure should be issued to clients. We have written about this before, most recently in connection with the Personalised Charges Communication that is now required to be issued to clients when full pension transfer advice is […]
We often see pension transfer cases where the client is in ill health and with this as the primary driver for transferring away from a defined benefits scheme, i.e. to make available a lump sum benefit in the event of death rather than the scheme dependants’ pensions. While this can be a strong driver for […]
A question that pops up from time to time is whether there is a need to discount potential options that are not being recommended. This was something that, in the early days of regulated advice, a few firms used to require advisers to include in suitability reports. Some still do. However, there has never been […]
Firms should have heads of compliance and money laundering reporting officers (MLROs) who are suitably competent and capable of effectively performing the roles. It is appropriate to carefully consider how individuals can demonstrate this ahead of seeking regulatory approval. The FCA have recently issued guidance which should help firms decide if an individual candidate is […]
Regulatory references are central to the Senior Managers & Certification Regime (SM&CR). They help firms make informed decisions about the fitness and propriety of individuals to whom they intend to assign Senior Management or Certification Functions (or appoint as non-approved Non-Executive Directors). In response to feedback on the challenges firms face when obtaining regulatory references, the FCA has […]
The riveting read that is the FCA’s 2021/22 Business Plan sets out their consumer priorities for the year ahead. One of these priorities is to enable consumers to make effective investment decisions as documented in the recently published Consumer Investment Strategy here . To those of us longer in the tooth, much of this has been seen […]
We have received details of the latest COVID survey from the FCA. See below for Tranche 2 dates. “Many of you will be aware that we issued the first phase of the Covid-19 Impact Survey in June 2020, covering around 13,000 firms across 15 Supervision portfolios (Tranche 1), and then rolled this out […]
We have completed the latest upgrade to ATEB Suitability on 14th January 2022. This update comes at no additional cost and provides major platform enhancements. Full details of the enhancements can be found below: Parent and Child Company Account Relationships Client firms can now be linked together to establish hierarchical group structures. This feature allows firms […]
The FCA is requesting that firms who have general insurance permissions (and premium finance providers), complete an online survey in relation to compliance with ICOBS 6B attestation. The deadline for submission is 31 March 2022, and attestation will need to be made by all firms who operate with the above permissions on a periodic basis. […]
Our new website is www.thistleinitiatives.co.uk. There will be no further posts here from ATEB Compliance. You can keep up to date with all of our usual regulatory and company updates here going forward.
Platform switching – is a suitability report required?
Alistair MacDougall Compliance 2018, 2019, 2020, 2021, exit fee, FCA, Pension, PI, platform, Switch
Platforms play a big part in the investment process of most UK firms. According to Defaqto, 94% of advisers place 50% or more of their new business on a platform, while as many as 20% choose not to place any client assets off-platform at all. That being the case, it is no surprise that the […]