Here’s an interesting quote:
“Of all the cases we have looked at over the last four or five years pretty much 100% of unsuitable cases came back with one of three answers; inadequate due diligence was one of those.”
Source: Rory Percival, FCA Technical Specialist
The FCA is therefore, not unsurprisingly, set to undertake a thematic review on due diligence for retail investment advice.
Mr. Percival gave some telling pointers:
- Advisers can rely on third party providers for factual information, but not for opinion. So for example, if the fund manager says this is what our asset allocation is and these are our top ten holdings, that is factual information that can be taken at face value. If however somebody says this is a low risk fund, you cannot take that at face value; you have to come to your own view on what that risk level is.
- Simply collecting off the shelf, due diligence material which has been provided by the platform providers, is an inappropriate tick box mentality and a lack of genuine regard for the client.
- For products, the focus would be on understanding the key risks and benefits of the product or the fund, “so that you understand what kind of clients it’s going to be suitable for”.
- For platforms the FCA would expect an impartial assessment of the options, taking into account the client bank circumstances, what services you want to provide to those clients and which platform or platforms in the market best fit those services.
Suitability reports – silver bullet, or not?
Paul Jay Compliance, Suitability DB Pension, FCA, MiFID, Pension, Pension Transfer, PI, transfer, Xplan
If you ask most advice firms which part of the advice process consumes the most time, most will reply: “Suitability Reports”. Based on the mammoth documents that some firms still produce, we can understand why. We do have some sympathy with firms though. On the one hand they’re told by the FCA that reports are […]