There is a specific rule requirement to disclose any possible disadvantages in the suitability report. The rule (COBS 9.4.7) can be seen here: http://fshandbook.info/FS/html/FCA/COBS/9/4.
Remember that a disadvantage is different to a risk. For example, there is a risk that investments can fall in value, whereas a disadvantage would be that the recommended product has higher charges than the product being replaced.
Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.
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For IFAs and Mortgage Brokers FCA rules and guidance state that: “Firms should ensure that those supervising employees ……. have the necessary coaching and assessment skills ….. to act as a competent supervisor and assessor.” To address this need, ATEB has updated its supervisor’s course in line with changes introduced at RDR. We have scheduled […]
The Mortgage Market Review (MMR) rules come into force exactly one year from today.
Those of you who attended the FSA Roadshows, or have read the articles on the FSA/FCA website, will be aware that the FCA are expecting all firms who advise on mortgages to be planning the implementation now. Indeed, they are tracking the progress of all mortgage regulated firms during Q2 2013 via an online survey (we do not believe the survey is open for completion yet).
The FSA requested in their email of 06th December 2012 that the professional standards data collection return for each firm had to be submitted by the 29th January and subsequently within 20 working days from the end of each quarter if there had been a change at the firm.
If there has been a change at your firm i.e. unqualified staff now qualified or a change in personnel then please ensure that the spreadsheet is completed and returned in time.
As you will be aware the FSA delayed their new capital resource requirements by a couple of years which means the changes come into effect this year.
The new requirements are being introduced over the next three years and are basically as follows. EBR is your ‘Expenditure Based Requirement’ i.e. the amount of fixed expenditure you need to hold as capital. The calculation is not straightforward; for further information, including additional requirements for subordinated loans please click here.
Identify, Assess & Manage
Steve Bailey Compliance FCA
Before you read on, what do you think the title refers to? The answer is Business Risks. The FCA has been highlighting this issue in workshops. They expect firms to ‘Identify, Assess & Manage’ risks and to be able to provide documentary proof that they are so doing. They expect firms to have at least […]