The FCA has published a Finalised Guidance document FG15_1 ‘Retail investment advice: Clarifying the boundaries and exploring the barriers to market development’ which it hopes will clarify the different types of sales models, the boundaries between them and the associated regulatory requirements.
The document can be downloaded here.
The paper outlines differences between advice models used by firms, or could be considering, and gives examples together with the FCA’s views as to whether they amount to a personal recommendation or not. It also draws together aspects from other recently issued guidance documents, for example the ‘fg 12_10 simplified advice’ and ‘fg 11_05 establishing the risk a customer is willing and able to take’, both have been featured in previous ATEB newsletter articles.
There is a useful table on page 22 that summarises the different distribution models, potential limitations and conditions associated to each. There is also useful guidance on what constitutes model portfolios and what is considered to be discretionary management.
It is relevant to all financial intermediary firms dealing in investments and also includes additional information and guidance for firms using social media.
The 47 page document is difficult to summarise, but there is some very useful content that all advisers and principals should understand.