Summary
What this article covers in 30 seconds
- Ongoing advice reviews are expected to form part of Consumer Duty MI.
- The FCA intends to contact firms about progress on ongoing advice services.
- Firms may need MI going back to 2018.
- David Boyhan links this to the FCA becoming data-led.
- Recordsure technology can support suitability reviews by automating document checks.
Recordsure’s Chief Product and Commercial Officer Garry Evans catches up with TCC’s regulatory expert and Technical Director David Boyhan to discuss the FCA’s release of its findings into its recent ongoing advice review. David specialises in wealth management and helps unpack what firms should know about the latest FCA publications regarding ongoing advice services.
In the fourth instalment of the five-part mini-series, Garry asks David how the review’s findings relate to the Consumer Duty.
Consumer Duty evidence
David says ongoing advice reviews are likely to form a key part of a firm’s Consumer Duty management information and feed into the annual board report. The FCA has confirmed it will contact firms later this year to see what progress they have made in relation to ongoing advice services.
Firms therefore need evidence to demonstrate any findings they show to the FCA. David says that if the FCA came knocking in six months’ time, a firm would need to show work completed on ongoing advice, MI going back to 2018, data about redress that may not have been paid to clients and an explanation of why.
He links this to TCC’s long-standing view that the FCA has become a data-led regulator. TCC encourages firms to have important MI backed by evidence to demonstrate that customers are treated fairly and receive good outcomes. In summary, work on ongoing advice is crucial to demonstrating Consumer Duty compliance.
Frequently asked questions
Garry Evans speaks with TCC Technical Director David Boyhan, a regulatory expert who specialises in wealth management.
David says they will form a key part of a firm’s Consumer Duty management information and feed into the annual board report.
He says firms may need MI going back to 2018, data on unpaid redress and explanations for why redress has not been paid.
Recordsure technology automates document checks and notifies firms when evidence is missing so advisers can intervene.