Summary
What this article covers in 30 seconds
- David Boyhan says firms need go-forward and backward-looking work.
- Current policies should support good ongoing service.
- Circa 90% of clients receive an ongoing service.
- Firms should review agreements, fair value assessments and disengagement.
- Historical MI should go back to 2018.
Following the FCA’s release of its findings into its recent ongoing advice review, TCC and Recordsure’s Chief Product and Commercial Officer Garry Evans catches up with TCC’s regulatory expert and Technical Director David Boyhan, who specialises in wealth management, to unpack the detail.
In the final instalment of the five-part mini-series, Garry asks David how can firms keep their ongoing advice services compliant.
Forward and backward-looking compliance work
David says there are two things firms need to do. The first is a go-forward piece, which is potentially the easier of the two. Firms should look at current policies and processes and make sure they are geared towards delivering a good ongoing service for clients. Circa 90% of clients receive an ongoing service, so it is essential that those clients receive good outcomes.
Firms should start by looking at client agreements to see what has been promised, then review fair value assessments and processes such as disengagement where clients are not engaging with the process. David says the FCA findings are positive, but there will be no excuses going forward now the FCA has released its thematic review findings. The FCA will expect policies and procedures to be compliant.
The second piece is backward-looking. Firms need to go back to 2018 and gather MI relating to clients who have not engaged with the process and clients who may not have been invited to engage with the process. They then need to take appropriate action, potentially including redress for relevant clients and disengagement.
David summarises that firms should consider both the go-forward and backward-looking pieces, ensuring that all clients historically have received good outcomes.
Frequently asked questions
He says firms need a go-forward piece covering current policies and processes, and a backward-looking piece covering historical MI and outcomes.
It should include client agreements, fair value assessments and processes such as disengagement where clients are not engaging.
David says circa 90% of clients receive an ongoing service, so firms must ensure those clients receive good outcomes.
He says firms should go back to 2018 and gather MI on clients who have not engaged or may not have been invited to engage, then take appropriate action.
Recordsure technology automates document checks and notifies firms when evidence is missing so advisers can intervene.